The U.S. Supreme Court first recognized municipal liability in police misconduct when it interpreted the term 'person,' as used in section 1983, to include a municipal government. Rather than explicitly articulating the extent of municipal liability, the Court established an analytical framework for municipal liability cases, while leaving the specifics to the lower courts. In Monell v. Department of Social Services of New York, the U.S. Supreme Court relied upon an express city policy to find municipal liability. In Rymer v. Davis, a suit alleging police misconduct, the Sixth Circuit Court extended 'Monell' to find municipal liability where no express policy existed. The court upheld a recovery against the city, ruling that the city's failure to train its police officers properly constituted gross negligence. It is consistent with the policy underlying municipal liability to hold a municipality ultimately responsible for police misconduct when the city, through either action or inaction, fails to minimize foreseeable abuses. 146 footnotes.