The United States Supreme Court in the City of Canton v. Harris (1989) held failing to train police officers may be the basis for managerial liability under Title 42 United States Code Section 1983. Using a content analysis, 1,525 Section 1983 lawsuits alleging failure to train were reviewed from 1989 to 1999. The research revealed ten frequent topic areas where the plaintiff regularly identifies police administrators as defendants. Emerging trends of this litigation and recommendations for police administrators are discussed.

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