After a 1978 traffic arrest, Geraldine Harris was brought to the Canton police station but no medical attention was provided. Harris was later taken to a nearby hospital where she was diagnosed as suffering from several emotional ailments. Harris sued the city of Canton and its officials, holding the city liable for violating her rights under the Fourteenth Amendment to receive necessary medical care while in police custody. The District Court issued a verdict against the city. The city appealed the court ruling, and the Sixth Circuit affirmed the District Court's analysis. However, the Court of Appeals stated that the plaintiff must prove that lack of training was reckless or grossly negligent to the point of depriving the individual of constitutional rights. The city then appealed to the U.S. Supreme Court, arguing that the Sixth Circuit's holding represented an impermissible broadening of municipal liability. The U.S. Supreme Court ruled in February 1989 that a municipality may be liable if city personnel are deliberately indifferent to constitutional rights and where 'failure to train' reflects a conscious choice or policy by a municipality. (See NCJ 117301-117302 for additional information)