After a 1978 traffic arrest, Harris was brought to the police station in Canton but no medical attention was provided. She was diagnosed later 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 attention while in police custody. The District Court issued a verdict against the city, and this verdict was upheld upon appeal. 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 U.S. Supreme Court ruled 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. This legal commentary on the U.S. Supreme Court decision concludes that the city of Canton had not been deliberately indifferent to Harris' constitutional rights, thus making it unnecessary to appeal the case. The commentary also points out that municipal liability for failure to train may be proper where it can be shown that policymakers are aware of and acquiesce to a pattern of constitutional violations involving the exercise of police discretion. (See NCJ 117300-117303 for additional information)