Opinion
Civil Action No. 02-10068-RWZ.
May 10, 2006
MEMORANDUM OF DECISION
City of Brockton police officers arrested and held plaintiff Clifford Montrond as a suspect in the alleged shooting of former Brockton police officer David Alexis. Upon determining not only that plaintiff was in fact working at the time of the alleged shooting but also that Mr. Alexis had fabricated the shooting report, the Brockton police released plaintiff. He filed the instant lawsuit against defendants City of Brockton and several Brockton police officers for violations of his rights secured under the United States and Massachusetts Constitutions and various state laws. Following a four-day trial, a jury found defendants not liable for any violations and, accordingly, awarded no damages to plaintiff.
One issue remains that did not go before the jury. Plaintiffs allege municipal liability by defendants City of Brockton and Chief of Police Paul Studenski for Mr. Alexis' conduct. Specifically, plaintiffs argue that these defendants failed to provide adequate training for officers to learn about reasonable methods for controlling and managing on-the-job stress, and that Mr. Alexis' inability to effectively handle severe stress resulted in the ultimate injury suffered by plaintiffs.
"[A]n allegation of a local government's failure to train police officers who then violate a plaintiff's constitutional rights can be actionable where `the failure to train amounts to deliberate indifference to the rights of persons with whom the police come into contact' and where `the identified deficiency in a city's training program [is] closely related to the ultimate injury.'" Young v. City of Providence, 404 F.3d 4, 26 (1st Cir. 2005). An important consideration is whether "the injury [would] have been avoided had the employee been trained under a program that was not deficient in the identified respect[.]" City of Canton, Ohio v. Harris, 489 U.S. 378, 391 (1989). In other words, plaintiff must show that the "deficiency in training actually caused the police officers' indifference. . . ." Id. Plaintiffs contend that Mr. Alexis labored under severe stress prior to the false shooting incident. Although Mr. Alexis consulted with defendants' stress officer, plaintiffs now question whether the individual had appropriate counselor training. Plaintiffs further point to defendants' lack of written policies, standards or guidelines on how to handle stress.
Even assuming arguendo that plaintiffs' assertions are true, they do not suffice to withstand summary judgment. First, it is unclear that liability for training programs properly includes programs on dealing with stress, as opposed to training for more concrete, measurable job-related skills. Without undermining the importance of stress management, I note that whether an officer successfully completes a stress program and whether a particular stress program may be considered objectively effective for most officers are unknowable and case-specific queries. The consequences of poorly managed stress are often unpredictable. This leads to the second difficulty with plaintiffs' argument, namely, that the record contains no evidence to support the theory that defendants' failure to provide adequate training for dealing with stress was related, much less closely related, to plaintiffs' injuries. Plaintiffs simply assert that "Alexis acted on his stress," but never places this claim in a factual context that would allow a jury to find that the absence of a stress management program at work actually caused the specific injuries suffered, or that the presence of an effective stress management program would have dissuaded Mr. Alexis from faking a shooting and framing plaintiff. (Pls.' Mem. in Opp. to Summ. J. 6).
Accordingly, defendants' Motion for Summary Judgment (# 94 on the docket) is allowed. Judgment may be entered for defendants.