Connick v. Thompson
United States Supreme Court
563 U.S. 51 (2011)
Prosecutors under Harry Connick (defendant) failed to disclose blood evidence exonerating John Thompson (plaintiff), who was wrongly convicted of armed robbery and, due to that conviction, chose not to testify in a separate murder trial where he was convicted and sentenced to death; the withheld evidence surfaced years later on death row, exonerating him after 18 years in prison. Thompson sued under § 1983 for failure to train prosecutors on disclosure obligations, and a jury awarded him $14 million, affirmed by the Fifth Circuit.
Whether, to be liable under 42 U.S.C. § 1983 for failure to train, a district attorney's office must be deliberately indifferent to a need for more or different training.