City of Oklahoma City v. Tuttle
United States Supreme Court
471 U.S. 808, 105 S. Ct. 2427, 85 L. Ed. 2d 791 (1985)
- Written by Salina Kennedy, JD
Facts
Julian Rotramel (defendant), an Oklahoma City police officer, shot and killed Albert Tuttle, a robbery suspect. Neither Rotramel nor any other Oklahoma City police officer had previously been involved in a similar shooting. Rose Marie Tuttle (plaintiff), Mr. Tuttle’s widow, filed an action against Rotramel and the City of Oklahoma City (city) (defendant), pursuant to 42 U.S.C. § 1983. Mrs. Tuttle alleged that Rotramel had deprived Mr. Tuttle of his constitutional rights and that the deprivation of rights was caused by a city custom or policy, making the city liable for Rotramel’s actions. At trial, the jury was instructed that, ordinarily, an unconstitutional municipal policy cannot be inferred from a single incident. However, the jury was also instructed that a single, extraordinarily excessive use of force might give rise to an inference that it was caused by inadequate training or supervision resultant from a municipal policy of deliberate indifference or gross negligence. The jury returned a verdict for Mrs. Tuttle, and the city appealed, arguing that the jury instructions had been erroneous. The court of appeals affirmed the verdict, and the United States Supreme Court granted certiorari to review the jury instructions.
Rule of Law
Issue
Holding and Reasoning (Rehnquist, J.)
Concurrence (Brennan, J.)
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