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Young v. City of Providence
Citations: 396 F. Supp. 2d 125; 2005 U.S. Dist. LEXIS 26399; 2005 WL 2860970Docket: C.A. No. 01-288S
Court: District Court, D. Rhode Island; November 2, 2005; Federal District Court
Leisa Young, as Administratrix of the Estate of Cornel Young, Jr., brought a case against the City of Providence and several police officers following the fatal shooting of Cornel Young Jr. by Providence Police officers Carlos Saraiva and Michael Solitro on January 28, 2000. Before trial, set to commence on November 7, 2005, the defendants filed motions for summary judgment, citing qualified immunity and other grounds. The Court, led by District Judge Smith, held oral arguments on September 19, 2005, and ultimately denied all motions for summary judgment. The background includes a bifurcated trial overseen by Judge Mary Lisi in 2003, where a jury found that Officer Solitro violated Cornel Young's Fourth Amendment rights, while Officer Saraiva did not. The initial rulings included the denial of defendants' motions under Rule 50 and the granting of summary judgment on several claims related to supervisory and municipal liability, as well as claims regarding training and state law. The First Circuit Court of Appeals affirmed the jury's verdict concerning Solitro's actions but reversed the summary judgment for the City regarding inadequate training related to the department's policy on officers’ readiness while off-duty. The District Court's summary judgment against Young regarding supervisory claims has been vacated and remanded for trial. Young alleges that the City and its officials—Prignano, Ryan, and Cohen—violated 42 U.S.C. § 1983 by inadequately training Officer Solitro, leading to a deprivation of Cornel's constitutional rights and exhibiting deliberate indifference. The First Circuit reversed the summary judgment against Providence related to the failure to train claim, which is critical for evaluating qualified immunity. The district court did not address key qualified immunity issues, including whether the underlying constitutional violation was clearly established and whether the supervisors' actions were objectively reasonable. The record on these issues is insufficiently developed, prompting the vacating of summary judgment for the supervisory defendants. Prignano, Cohen, and Ryan are now seeking summary judgment on qualified immunity and other grounds. The legal standard for summary judgment requires the absence of genuine material fact disputes. Qualified immunity protects public officials from civil liability as long as their actions were reasonably consistent with the rights in question. The court must evaluate qualified immunity claims in a specific order, starting with whether the alleged facts demonstrate a constitutional violation. The court must first ascertain if the claimed right was 'clearly established' at the time of the alleged violation. If so, it then evaluates whether a reasonable official in the same position as the defendants would have recognized that their actions violated that established law. Qualified immunity shields officials from liability if their misunderstanding of the law's requirements is deemed reasonable. Young seeks to hold Prignano, Ryan, and Cohen accountable for their supervisory roles in training Solitro. Prignano, as Chief of the PPD, oversaw the training program; Ryan, as Director of Administration and a training instructor, was involved in developing the curriculum; and Cohen directed the Training Academy attended by Solitro. In the context of supervisory liability, the qualified immunity analysis is refined into two parts under the 'clearly established' prong: one assesses if a constitutional right was violated by a subordinate, and the other examines if it was established that supervisors could be liable for their subordinates' constitutional violations. The inquiry into objective legal reasonableness also shifts, requiring consideration of whether the supervisor should have understood that their actions could jeopardize the plaintiff's constitutional rights. This analysis intertwines the qualified immunity and merits assessments, particularly through the deliberate indifference standard. For the first prong, Young must demonstrate that the officer's conduct violated a constitutional right, which she has accomplished, as evidenced by a unanimous jury verdict confirming that Solitro violated Cornel Young Jr.'s constitutional rights, upheld by the First Circuit. However, Ryan and Cohen argue that the relevant constitutional violation for prong one pertains to the adequacy of training provided to Solitro, rather than the shooting incident itself. The excerpt addresses the qualified immunity analysis in a case involving a claim of failure to train against the City and its supervisors. It emphasizes that the first prong of the inquiry remains unchanged despite the nature of the claim, indicating that Young has satisfied her burden under this prong. The second prong focuses on whether the law was clearly established at the time of the constitutional violation. This prong involves two inquiries: the first assesses if the constitutional right violated by the subordinate was clearly established at the time of the incident, while the second determines if it was clearly established that a supervisor could be held liable for failing to train officers in avoiding such situations. Defendants attempt to narrow the inquiry to whether there is a clearly established right to be free from friendly fire during on-duty/off-duty confrontations, hoping to complicate Young's argument. Citing Anderson v. Creighton, the text stresses that a right must be clearly established in a particularized manner, ensuring that a reasonable official understands what constitutes a violation. It clarifies that while prior cases do not need to match exactly, the unlawfulness must be apparent based on existing law. The right to be free from unreasonable seizure is affirmed as clearly established under the Fourteenth Amendment, thereby confirming that the shooting of Cornel constituted a violation of this right. The second inquiry assesses whether a reasonable police supervisor would understand that failing to provide adequate training on on-duty/off-duty confrontations could lead to liability for unconstitutional actions by subordinates. Thus, the court must evaluate the clarity of legal rights and obligations relevant to the supervisor's conduct at the time of the incident. Defendants contend that Young's inability to cite cases involving supervisory liability under Section 1983 for friendly fire incidents indicates that a reasonable supervisor would not be aware of the unlawfulness of their conduct. Young argues that it is sufficient to demonstrate that the law is clearly established concerning a supervisor's liability for subordinates’ constitutional violations resulting from inadequate training. The defendants' assertion that a reasonable supervisor would not realize their potential liability is dismissed as baseless. Established legal precedent holds that a deliberately indifferent supervisor can be held liable for constitutional violations by subordinates, particularly regarding failure to train. The Court of Appeals previously rejected a similar argument, affirming that officials can be on notice of legal violations even in novel situations and that prior cases do not need to be fundamentally similar. The absence of previous friendly fire cases does not exempt the defendants from liability, as it would impose an unreasonable burden on plaintiffs to cite exact prior cases involving the same conduct. Notably, the Court indicated that a jury could determine the department recognized a significant risk of friendly fire incidents without specific training, especially with an always armed/always on-duty policy. Expert testimony could support the notion that the police community understood the substantial risk of such incidents and the necessity for targeted training. Furthermore, Young presented evidence of past misidentifications by officers, particularly affecting minority personnel, which indicated the department's awareness of the issue. Thus, when Cornel was shot, it was clearly established that supervisors could be liable for failing to train officers adequately on avoiding misidentifications during armed confrontations. Young has satisfied her burden regarding the second prong of the qualified immunity analysis. For the third prong, she must demonstrate a material dispute of fact regarding whether each defendant acted in an objectively unreasonable manner. Conduct can only be deemed unprotected by qualified immunity if it demonstrates deliberate indifference, which requires Young to establish: (1) a grave risk of harm, (2) the defendant's actual or constructive knowledge of that risk, and (3) a failure to take readily available measures to mitigate the risk. Officers are shielded by qualified immunity when they make reasonable mistakes about the constitutionality of their actions. Consequently, qualified immunity protects all but those who are plainly incompetent or who knowingly violate the law. Young must prove material factual disputes regarding each defendant's deliberate indifference. Young's burden is somewhat alleviated because the conduct in question—failure to provide adequate training—does not invoke the more lenient reasonableness standard applicable to police actions in urgent circumstances. The alleged inadequate training stemmed from supervisory decisions over time, not from immediate, high-pressure situations, all while adhering to the always armed/always on-duty policy. Young argues that the Court of Appeals' reversal of summary judgment on the Monell claim against the City necessitates a denial of qualified immunity for each defendant since both claims involve the same deliberate indifference standard. However, the qualified immunity assessment must focus specifically on each defendant’s involvement with Solitro's training and whether a jury could find their actions objectively unreasonable. It hinges on whether a similarly situated supervisor would recognize that their training conduct jeopardized Cornel's constitutional rights. Regarding Prignano, the Chief of the PPD, Young claims he failed to ensure proper training and maintained the always armed/always on-duty policy despite being aware of its potential dangers. Evidence supports Young's allegations, as Prignano acknowledged his responsibility for PPD training and recognized the policy's risks. After Cornel's death, Prignano did not change the policy, and the Court of Appeals found substantial evidence of training deficiencies and the associated risks. Although the appellate court focused on municipal liability, its findings are pertinent to assessing Prignano's deliberate indifference as the Chief responsible for training. The court identified significant factual disputes regarding the adequacy of the training provided, including a lack of documentation and Prignano's implication that no training was necessary. Cohen, the Training Academy Director, was uncertain about the existence of training on on-duty/off-duty interactions, which other PPD officers also reported experiencing little to no training on. The Court of Appeals highlighted that Young presented evidence indicating the always armed/always on-duty policy was 'inherently dangerous' and that its risks were well-known within the police community, necessitating thorough training to prevent accidental shootings among off-duty officers. Young's testimony suggested that without specific training and protocols, both public and officer safety could be compromised. Prignano, as Chief of the PPD, could be inferred to have knowledge of these training needs, which are relevant to his claim of objectively reasonable behavior. He argued that he did not directly influence training as he did not teach at the Training Academy and relied on Captain Ryan, who oversaw it, citing Ryan's qualifications as justification. However, Prignano could still be liable as a supervisor, particularly if he had actual knowledge of inadequate training or was willfully blind to the risks involved. The comparison to Manarite v. City of Springfield was deemed inappropriate, as that case involved proactive measures taken by the police chief, contrasting with Prignano's inaction regarding the inherent dangers of the always armed/always on-duty policy. Prignano's assertion of some training provided for on-duty/off-duty misidentifications was insufficient, as it suggested a need to interpret facts favorably for him, contrary to summary judgment standards. Young successfully established material factual issues concerning Prignano's duty regarding training and awareness of the risks linked to the policy, potentially indicating deliberate indifference. Ryan, as Director of Administration, had oversight of the training division but argued his role was limited to selecting effective instructors and therefore did not exhibit deliberate indifference. He contended that this should afford him qualified immunity. Young provides evidence indicating that Ryan was actively involved in training at the Training Academy, contrary to PPD policy, specifically by instructing officers against taking off-duty action. Despite recognizing this policy conflict, Ryan claimed his training emphasized liability rather than safety. He was unaware of any training related to the always armed/always on-duty policy, suggesting a lack of consistent protocols that could lead to adverse outcomes. PPD Chief Prignano's deposition undermines Ryan's claims of limited responsibility, as he characterized Ryan as the primary authority on training, responsible for instructor selection and content. Material factual disputes exist regarding Ryan's role, suggesting he may have been deliberately indifferent to training deficiencies impacting constitutional rights. Cohen, as the Training Academy Director, is accused of deliberate indifference due to his lack of awareness about training on on-duty/off-duty interactions, despite expert testimony highlighting the critical difference between on-duty and off-duty police actions. Cohen argues he merely administered a training curriculum and emphasizes the absence of friendly fire incidents during his tenure. He contends he cannot be liable as a supervisor since he did not teach directly, but as the head of the Academy, he may still be liable under § 1983 for inadequate training. Additionally, Cohen claims some training on these interactions existed, pointing to six months of training that included scenario-based exercises. However, the court rejects attempts to draw favorable inferences for Cohen and indicates that he cannot evade liability based on his supervisory role. The Court of Appeals indicated that the jury could find either minimal or no effective training regarding on-duty/off-duty interactions. Cohen expressed uncertainty about the existence of any training program, questioning how a police officer could assess constitutional adequacy of training amid judicial disagreements. Notably, Judge Lisi's ruling that Young failed to demonstrate constitutional deficiencies in the training was overturned by the Court of Appeals, which noted that a jury might find training inadequate. However, the appellate ruling focused on municipal, not supervisory, liability, clarifying that the critical issue was whether the City displayed deliberate indifference to potential risks. Cohen's argument, which compared the training received by officers Saraiva and Solitro, was deemed irrelevant to the jury's determination of constitutional rights violations, as the training adequacy was not under consideration. The jury could conclude that Cohen, as the Training Academy Director, was deliberately indifferent to the risks tied to the always armed/always on-duty policy due to a lack of training, potentially endangering officers' lives. Young satisfied all three prongs of the qualified immunity test, thus denying Prignano, Ryan, and Cohen immunity. Young also asserted a Monell claim against Prignano in his official capacity as a policymaker regarding police training. Prignano argued for summary judgment, claiming he was not a current City employee and not a "final policymaker" even if he were. He asserted that only the Mayor and City Council held that authority. Young countered that under Rhode Island law, the PPD Chief is indeed a "final policymaker" for training aspects relevant to Monell liability. Municipalities can be liable under 42 U.S.C. § 1983 for actions taken by officials whose decisions represent official policy, as established in Monell v. Department of Social Services. Only those with "final policymaking authority" can expose the municipality to liability, as reiterated in City of St. Louis v. Praprotnik and Pembaur v. City of Cincinnati. The determination of whether a Chief holds final policymaking authority is a question for the court, governed by state law. The court notes that Prignano and Young, involved in the case, reference previous court decisions and the Home Rule Charter of Providence to support their arguments. Judge Lisi concluded that the Monell "policy" claim was redundant to the custom and practice claim against the City, merging both into Count III. The court acknowledges the distinction between "policy" and "custom" is largely nominal in this context and indicates that the jury will ultimately decide if the City's actions were the legal cause of a constitutional rights violation. Despite the minimal practical difference, the court will evaluate Prignano's final policymaking authority concerning police training issues. The First Circuit has adopted a "final authority" approach to assess municipal liability, allowing for cases where policymaking is shared among officials. Moreover, delegating policymaking authority does not exempt municipalities from liability. A final policymaker's authority does not require formal official status; such authority can be inferred from a consistent pattern of acquiescence by the governing body towards an agency or official's exercise of policymaking power. In this context, the Court of Appeals clarified that while it was uncertain if Chief Prignano was a final policymaker regarding police training, Commissioner Partington was definitively identified as such due to his broad delegations of authority from the municipality. The inquiry into state law regarding this issue is partly resolved by the Court of Appeals' determination that Partington held final policymaking authority over police training. Despite the U.S. Supreme Court's assertion that state law would typically identify the relevant policymaking body, no applicable Rhode Island General Law or Supreme Court ruling has been cited. The Sean Patrick case, which involved Chief Prignano's decision to deploy officers at a nightclub, was noted by Senior Judge Ronald Lagueux, who concluded that this action did not reflect a policy established by the City’s top authorities. The Court of Appeals emphasized that Partington was recognized as a final policymaker, and the single decision made by Prignano did not constitute a city-wide policy capable of incurring liability under Section 1983. In contrast, the policy pertinent to the current case was longstanding, affecting all police recruits and officers, and underwent annual review. Additionally, the City Charter delineates the Mayor's supervisory powers over city departments and assigns the commissioner as the head of the police department, who appoints the chief of police, thereby establishing the hierarchy of authority within the police department. Section 1001 outlines the commissioner's specific authorities, including oversight of PPD personnel and the ability to establish rules for the police department's management. City department heads can appoint deputies without requiring external approval, and these deputies perform duties as directed by the heads. However, the department heads' supervisory powers are subject to the mayor's direction unless stated otherwise, and they may delegate functions with the mayor's approval. Partington, identified as a final policymaker by the Court of Appeals, shared policymaking responsibilities with Prignano, the Chief, as evidenced by Partington's deposition. He indicated that the mayor did not need to approve PPD policies and delegated training authority to the Chief. Partington also suggested that the Chief's non-action could hinder necessary reforms within the PPD. Prignano confirmed his ultimate responsibility for training within his command and affirmed the necessity for clear policies and procedures for officers. The change to the always armed/always on-duty policy, issued on PPD letterhead and signed by both the Commissioner and the Chief, further illustrates that the Chief shared policymaking authority regarding this policy. At the summary judgment stage, all facts and reasonable inferences must be viewed in favor of Young. Young has provided sufficient evidence indicating that Chief Prignano had final policymaking authority regarding training issues, which may expose the City to Monell liability under Section 1983. Ryan argues for summary judgment based on the First Circuit’s affirmation that Saraiva did not violate Cornel's constitutional rights, claiming he cannot be liable if Saraiva is not. However, Ryan's argument is redundant to his qualified immunity claim and requires minimal discussion. His supervisory responsibilities extended beyond his role as the Director of the Training Academy, as he also served as Director of Administration for Solitro's Academy, overseeing the training division. Ryan maintained an active role in the police department's training program and taught classes, including one on civil liability, where he instructed officers not to intervene while off duty, contradicting PPD policy. This could lead a jury to believe that Solitro acted under the misapprehension that off-duty officers should not engage in certain situations. Supervisory liability applies not only to those directly instructing but also to various officials associated with rights-violating behavior. Consequently, Ryan's attempt to distance himself from Solitro's training is unsuccessful, and his motion for summary judgment is denied. The motions for summary judgment from Defendants Prignano, Ryan, and Cohen are all denied. Summary judgment for Defendant Richard Sullivan was previously agreed upon and warrants no further discussion. The court will refer to specific PPD regulations collectively as the "always armed/always on-duty policy," in alignment with the Court of Appeals' terminology. The excerpt addresses the qualified immunity analysis, specifically noting that the district court did not rule on the second and third prongs, which concern the clarity of both the constitutional violation and the supervisory liability. The Court of Appeals indicated that the first prong seemed satisfied, as a jury found that Officer Solitro violated Cornel's constitutional rights, a verdict upheld on appeal. Prignano asserts that the rights related to friendly fire and supervisory training were not clearly established at the time of the incident. Ryan and Cohen incorrectly characterized the underlying violation as insufficient training. The law does not require that the specific conduct be previously deemed unlawful, but this is contested by Prignano's statement regarding a review of training curricula. Additionally, despite Ryan's claim of responsibility for training consistency, there is evidence of prior reprimand involving Cornel for inaction during a shooting incident. The distinction between being instructed to act for safety versus liability reasons appears inconsequential. Ryan's contradictory instruction likely influenced the Court of Appeals' conclusion that training on the always armed/always on-duty policy was necessary due to officers' unclear understanding of the policy. Judge Lisi reviewed Young’s Monell claim against Prignano and determined that Count IV was included within Count III, a decision not appealed, leaving the Court of Appeals to focus on Count III. Prignano's assertion that a suit against him in his official capacity is not a suit against the city merits little discussion, as such claims are treated as claims against the governmental entity itself, regardless of his current employment status. The text references challenges in cases where a municipal policymaker delegates authority to another official and notes that Rhode Island law outlines specific duties of a police chief. A Rhode Island Superior Court Justice recently found that the Acting Director of the Department of Public Property held final policymaking authority for school site selection regarding Monell liability. This situation remains valid despite the Sean Patrick ruling stating that the Mayor and City Council are the highest authorities. The Superior Court also deemed Sean Patrick's ruling inapplicable to the case at hand. The discussion regarding the order does not imply its admissibility at trial; that decision is reserved for trial proceedings. The Court does not need to determine whether the final policymaking authority belonged solely to the Chief or was shared with the commissioner. Additionally, the First Circuit indicated that the training conducted in the 57th Academy, which Ryan led, could be relevant to demonstrating that Solitro's inadequate training was part of a broader policy failure rather than occasional negligence in an otherwise sound program.