The standard established by the United States Supreme Court in Monell v. New York City Department of Social Services focuses solely on the constitutional conduct of municipal policymakers. In the 1989 decision in City of Canton, Ohio v. Harris, the Court adopted a standard based on deliberate indifference by city policymakers to the constitutional rights of persons contacted by police officers. Federal appellate cases have also held that police managers are only liable in the case of constitutional violations resulting from deliberate indifference to the rights of others. To minimize their liability, police agencies should carefully review their training regarding high-risk activities such as the use of force. They should also periodically review supervisory policies relating to citizen complaints and departmental disciplinary actions. 17 reference notes.