To define what police training is necessary requires a balance between the government's duty and the citizen's rights. Training is most essential to police success. In 1965, fewer than 15 percent of all police agencies provided their recruits with any instruction. Today, agencies that have committed resources to training and experimented with alternative approaches are demonstrably better than those who accord training a lower priority. In Canton vs. Harris, the U.S. Supreme Court ruled that the municipality was not liable, as the inadequacy of police training could not be linked to deliberate indifference by particular officers. A municipality can reasonably be said to be "deliberately indifferent," and therefore liable, if the origins of constitutional rights violations can be traced back to obvious faults in municipal policy. The Court defined deliberate indifference by balancing policy, actual performance demands, and training -- all of which differ from department to department. The recent increase in plaintiffs' use of the Federal courts to protect their civil and constitutional rights may have caused police departments to adopt stricter hiring and training practices. 41 notes.