Respond to at least 1 of the following ethical cases. What would you do/recommend? Inform your response with readings.

1. You've just taken over as Executive Director for a nonprofit community foundation that, among other things, supplies critical funds to local nonprofits. Prior to your arrival, a family member of one of the largest (now deceased) donors became good friends with the former executive director. The family member was allowed, more and more over time, to advise how the dollars in the deceased's fund should be used and allocated -- even though the actions and ultimate decisions when against organizational policy as there was a signed fund agreement between the organization and the donor with very specific intentions. For some reason, the former executive director did not follow the legality of the intentions stated in the fund agreement. As the new executive director, you are tasked with the decision on how to handle this complex situation. The family member of the donor thinks that he has the authority and power to determine which organizations should receive money. He is unhappy with the community foundation for trying to limit his control of the fund. What do you do?

2. You work in an historical building that does not wheelchair access. You've raised this issue for yourself (you have family members who could never visit you at work because they use wheelchairs) and others. Management responds that the issue is complicated because the building is covered by historical preservation laws that don't require accommodations. The ethical dilemma here is how does Americans with Disabilities Act (ADA), which does require accessibility accommodations, and a town's historic preservation agency or historical commission work together? The law requires that all employers to provide reasonable accommodations(Links to an external site.) to employees with disabilities however, the Historical Commission doesn't allow any renovations to old buildings that have no elevator or ramps. Who should triumph here, the ADA or the Historical Commission? What do you do?

Approved by the ASPA National Council 3/16/13 PRACTICES TO PROMOTE THE ASPA CODE OF ETHICS The ASPA Code of Ethics is a statement of the aspirations and high expectations of public servants. These practices serve as a guide to behavior for members of ASPA in carrying out its principles. The Code and these practices are intended to be used as a whole and in conjunction with one another. An ethical public servant will consider the full range of standards and values that are relevant to handling a specic matter and be committed to upholding both the spirit and the letter of this code. ASPA members are committed to: 1. Advance the Public Interest. Promote the interests of the public and put service to the public above service to oneself. a. Seek to advance the good of the public as a whole, taking into account current and long- term interests of the society. Exercise discretionary authority to promote the public interest. Be prepared to make decisions that may not be popular but that are in the public's best interest. Subordinate personal interests and institutional loyalties to the public good Serve all persons with courtesy, respect, and dedication to high standards. 2. Uphold the Constitution and the Law. Respect and support government constitutions and laws, while seeking to improve laws and policies to promote the public good. a. Recognize and understand the constitutional, legislative and regulatory framework in which you work and fully discharge your professional roles and responsibilities. Promote constitutional principles of equality, fairness, representativeness, responsiveness and due process in protecting citizens' rights and promoting the public good. Develop proposals for sound laws and policies and for improving or eliminating laws and policies that are unethical, counterproductive, or obsolete. Respect and safeguard protected and condential information. 3. Promote democratic participation. Inform the public and encourage active engagement in governance. Be open, transparent and responsive, and respect and assist all persons in their dealings with public organizations. a. b. c. Be open and transparent while protecting privacy rights and security. Recognize and support the public's right to know the public's business. Involve the community in the development, implementation, and assessment of policies and public programs, and seek to empower citizens in the democratic process, including special assistance to those who lack resources or inuence. 131 S.Ct. 1350 (2011) Harry F. CONNICK, District Attorney, et al., Petitioners, V. John THOMPSON. No. 09-571. Supreme Court of United States. Argued October 6, 2010. Decided March 29, 2011. 1355 *1355 Stuart K. Duncan, Baton Rouge, LA, for Petitioners. Gordon Cooney, Jr., Philadelphia, PA, for Respondent. James D. "Buddy" Caldwell, Louisiana Attorney General, S. Kyle Duncan, Ross W. Bergethon, Robert Abendroth, Assistant Attorneys General, Louisiana Department of Justice, Baton Rouge, LA, Leon A. Cannizzaro, Jr., Orleans Parish District Attorney, Graymond F. Martin, First Assistant District Attorney, Donna R. Andrieu. New Orleans, LA, for Petitioners. R. Ted Cruz, Allyson N. Ho, Morgan, Lewis & Bockius LLP, Houston, Texas, Michael L. Banks, J. Gordon Cooney, Jr., Morgan, Lewis & Bockius LLP, Philadelphia, Pennsylvania, for Respondent. Justice THOMAS delivered the opinion of the Court. The Orleans Parish District Attorney's Office now concedes that, in prosecuting respondent John Thompson for attempted armed robbery, prosecutors failed to disclose evidence that should have been turned over to the defense under Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963). Thompson was convicted. Because of that conviction Thompson elected not to testify in his own defense in his later trial for murder, and he was again convicted. Thompson spent 18 years in prison, including 14 years on death row. One month before Thompson's scheduled execution, his investigator discovered the undisclosed evidence from his armed robbery trial. The reviewing court determined that the evidence was exculpatory, and both of Thompson's convictions were vacated. After his release from prison, Thompson sued petitioner Harry Connick, in his official capacity as the Orleans Parish District Attorney, for damages under Rev. Stat. $ 1979, 42 U.S.C. $ 1983. Thompson alleged that Connick had failed to train his prosecutors adequately about their duty to produce exculpatory evidence and that the lack of training had caused the nondisclosure in Thompson's 1356 robbery case. The jury awarded Thompson $14 million, and *1356 the Court of Appeals for the Fifth Circuit affirmed by an evenly divided en banc court. We granted certiorari to decide whether a district attorney's office may be held liable under $ 1983 for failure to train based on a single Brady violation. We hold that it cannot.1357 A In early 1985. John Thompson was charged with the murder of Raymond T. Liuzza, Jr. in New Orleans. Publicity following the murder charge led the victims of an unrelated armed robbery to identify Thompson as their attacker. The district attorney charged Thompson with attempted armed robbery. As part of the robbery investigation. a crime scene technician took from one of the victims' pants a swatch of fabric stained with the robber's blood. Approximately one week before Thompson's armed robbery trial. the swatch was sent to the crime laboratory. Two days before the trial, assistant district attorney Bruce Whittaker received the crime lab's report, which stated that the perpetrator had blood type B. There is no evidence that the prosecutors ever had Thompson's blood tested or that they knew what his blood type was. Whittaker claimed he placed the report on assistant district attorney James Williams' desk, but Williams denied seeing it. The report was never disclosed to Thompson's counsel. Williams tried the armed robbery case with assistant district attorney Gerry Deegan. On the rst day of trial, Deegan checked all of the physical evidence in the case out of the police property room, including the blood-stained swatch. Deegan then checked all of the evidence but the swatch into the courthouse property room. The prosecutors did not mention the swatch or the crime lab report at trial, and the jury convicted Thompson of attempted armed robbery. A few weeks later, Williams and special prosecutor Eric Dubelier tried Thompson for the Liuzza murder. Because of the armed robbery conviction, Thompson chose not to testify in his own defense. He was convicted and sentenced to death. W. In the 14 years following Thompson's murder conviction, state and federal courts reviewed and denied his challenges to the conviction and sentence. See x r I. Th L .4 2 W; W. The State scheduled Thompson's execution for May 20, 1999. In late April 1999, Thompson's private investigator discovered the crime lab report from the armed robbery investigation in the les of the New Orleans Police Crime Laboratory. Thompson was tested and found to have blood type 0, proving that the blood on the swatch was not his. Thompson's attorneys presented this evidence to the district attorney's ofce, which, in turn, moved to stay the execution and vacate Thompson's armed robbery convictionm The Louisiana Court of Appeals then reversed Thompson's murder conviction, concluding that the armed robbery *1357 conviction unconstitutionally deprived Thompson of his right to testify in his own defense at the murder trial. gate W. In 2003, the district attorney's ofce retried Thompson for Liuzza's murderm The jury found him not guilty. 1358 Thompson then brought this action against the district attorney's ofce, Connick, Williams, and others, alleging that their conduct caused him to be wrongfully convicted, incarcerated for 18 years, and nearly executed. The only claim that proceeded to trial was Thompson's claim under 1983 that the district attomey's ofce had violated Brady by failing to disclose the crime lab report in his armed robbery trial. See W. Thompson alleged liability under two theories: (1) the Brady violation was caused by an unconstitutional policy of the district attomey's ofce: and (2) the violation was caused by Connick's deliberate indifference to an obvious need to train the prosecutors in his ofce in order to avoid such constitutional violations. Before trial, Connick conceded that the failure to produce the crime lab report constituted a Brady violationm See Record EX608, EX880. Accordingly, the District Court instructed the jury that the "only issue" was whether the nondisclosure was caused by either a policy, practice, or custom of the district attorney's office or a deliberately indifferent failure to train the ofce's prosecutors. Record 1615. Although no prosecutor remembered any specic training session regarding Brady prior to 1985, it was undisputed at trial that the prosecutors were familiar with the general Brady requirement that the State disclose to the defense evidence in its possession that is favorable to the accused. Prosecutors testied that ofce policy was to turn crime lab reports and other scientic evidence over to the defense. They also testied that, after the discovery of the undisclosed crime lab report in 1999, prosecutors disagreed about whether it had to be disclosed under Brady absent knowledge of Thompson's blood type. The jury rejected Thompson's claim that an unconstitutional office policy caused the Brady violation, but found the district attomey's ofce liable for failing to train the prosecutors. The jury awarded Thompson $14 million in damages, and the District Court added more than $1 million in attorney's fees and costs. After the verdict, Connick renewed his objectionwhich he had raised on summary judgmentthat he could not have been deliberately indifferent to an obvious need for more or different Brady training because there was no evidence that he was aware of a pattern of similar Brady violations. The District Court rejected this argument for the reasons that it had given in the summaryjudgment order. In that order, the court had concluded that a pattern of violations is not necessary to prove deliberate indifference when the need for training is "so obvious." No. Civ. A. 03-2045 (ED La., Nov. 15, 2005), App. to Pet. for Cert. 141a, 2005 WL 3541035, '13. Relying on Qanan v. Harris 459 u.. Q75, 19$ Wthe *1358 court had held that Thompson could demonstrate deliberate indifference by proving that "the DA's ofce knew to a moral certainty that assistan[t] [district attorneys] would acquire Brady material, that without training it is not always obvious what Brady requires, and that withholding Brady material will virtually always lead to a substantial violation of constitutional rightsM-l App. to Pet. for Cert. 141a, 2005 WL 3541035, '13. A panel of the Court of Appeals for the Fifth Circuit afrmed. The panel acknowledged that Thompson did not present evidence of a pattern of similar Bradyviolations, 553 F.3d 836, 851 (2008), but held that Thompson did not need to prove a pattern. id, at 854. According to the panel, Thompson demonstrated that Connick was on notice of an obvious need for Brady training by presenting evidence \"that attorneys, often fresh out of law school, would undoubtedly be required to confront 1359 Brady issues while at the DA's Ofce, that erroneous decisions regarding Brady evidence would result in serious constitutional violations, that resolution of Brady issues was often unclear, and that training in Bradywould have been helpful," 553 F.3d, at 854. The Court of Appeals sitting en banc vacated the panel opinion, granted rehearing. and divided evenly, thereby afnning the District Court. 578 F.3d 293 (C.A.5 2009) (per curiam). In four opinions, the divided en banc court disputed whether Thompson could establish municipal liability for failure to train the prosecutors based on the single Brady violation without proving a prior pattern of similar violations, and. if so. what evidence would make that showing. We granted oertiorari. 559 US. _, 130 S.Ct. 1880, 176 L.Ed.2d 399 (2010). The Brady violation conceded in this case occurred when one or more of the four prosecutors involved with Thompson's armed robbery prosewtion failed to disclose the crime lab report to Thompson's counsel. Under Thompson's failureto-train theory, he bore the burden of proving both (1) that Connlck, the policymaker for the district attorney's ofce, was deliberately indifferent to the need to train the prosecutors about their Brady disclosure obligation with respect to evidence of this type and (2) that the lack of training actually caused the Brady violation in this case. Connick argues that he was entitled to judgment as a matter of law because Thompson did not prove that he was on actual or constructive notice of, and therefore deliberately indifferent to, a need for more or different Brady training. We agreel A Title 42 U.S.C. 1983 provides in relevant part: '1359 "Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State . . . subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law. suit in equity. or other proper proceeding for redress . . . ." A municipality or other local government may be liable under this section if the governmental body itself "subjects" a person to a deprivation of rights or \"causes\" a person "to be subjected" to such deprivation. See W (19751. But, under 1983, local governments are responsible only for "their own illegal acts." Pembagr v Cincinnati 475_u S 469 479 10l 1192 W 431193.61 (citing mm W). They are not vicariously liable under 1983 for their employees' actions. See id., at 691, 98 S.Ct. 2018; W; W W (collecting 03595)- Plaintiffs who seek to impose liability on local governments under 1983 must prove that "action pursuant to ofcial municipal policy\" caused their injury. WWW; see 1360 id., at 694, 98 S.Ct. 2018. Ofcial municipal policy includes the decisions of a government's lawmakers, the acts of its policymaking ofcials. and practices so persistent and widespread as to practically have the force of law. See ibidi; Wt 480-481. 106 S.Ct. 129;; Am v. StH. Kless_& Co. 39811.8 144 167-163 9_0_$.Qi 1538 W 14211970). These are "action[s] for which the municipality is actually responsible." W. In limited circumstances, a local government's decision not to train certain employees about their legal duty to avoid violating citizens' rights may rise to the level of an ofcial government policy for purposes of 1983. A municipality's culpability for a deprivation of rights is at its most tenuous where a claim turns on a failure to train. See W W ("[A] 'policy' of 'inadequate training'" is 'far more nebulous, and a good deal further removed from the constitutional violation, than was the policy in Monell'). To satisfy the statute, a municipality's failure to train its employees in a relevant respect must amount to "deliberate indifference to the rights of persons with whom the [untrained employees] come into contact." Qagtgn 49 L1.., at 388 109 .Q. 1197. Only then "can such a shortcoming '1360 be properly thought of as a city 'policy or custom' that is actionable under 1983.\" Id., at 389, 199 $.91. JlQZ- "'[D]e|iberate indifference' is a stringent standard of fault, requiring proof that a municipal actor disregarded a known or obvious consequence of his action." Baa" Q14, 529 Ll- at 419 117 Qt. 1181. Thus, when city policymakers are on actual or constructive notice that a particular omission in their training program causes city employees to violate citizens' constitutional rights, the city may be deemed deliberately indifferent if the policymakers choose to retain that program. Id., at 407, 11 Z S 12 mg. The city's "policy of inaction" in light of notice that its program will cause constitutional violations "is the functional equivalent of a decision by the city itself to violate the Constitution." ntgn 49 u.., at 395 199 sg. 1197 (Q'annor ,1. mncurring in part and dissenting in gag). A less stringent standard of fault for a failure-to-train claim "would result in de facto respondeat superior liability on municipalities . . . ." Id., at 392, 109 S.Ct. 1197; see also Pembaur supra at 483, 106 S.Ct. 1292 jopinign of Brennan ,1.j("[M]unicipal liability under 1983 attaches whereand only wherea deliberate choice to follow a course of action is made from among various alternatives by [the relevant] ofcials. . ."). A pattern of similar constitutional violations by untrained employees is "ordinarily necessary" to demonstrate deliberate indifference for purposes of failure to train. W scum. Policymakers' "continued adherence to an approach that they know or should know failed to prevent tortious conduct by employees may establish the conscious disregard for the consequences of their actionthe 'deliberate indifference'neoessary to trigger municipal liabi at 407, 117 $.91. 12. Vlthout notice that a course of training is decient in a particular respec decisionmakers can hardly be said to have deliberately chosen a training program that will caus violations of constitutional rights. Although Thompson does not contend that he proved a pattern of similar Bradyviolations, 553 F.3d, 1361 at 851. vacated, 578 F.3d 293 (en banc). he points out that, during the ten years preceding his armed robbery trial, Louisiana courts had overturned four convictions because of Brady violations by prosecutors in Connick's ofceJ-el Those four reversals could not have put Connick on notice that the ofce's Brady training was inadequate with respect to the sort of Brady violation at issue here. None of those cases involved failure to disclose blood evidence, a crime lab report, or physical or scientic evidence of any kind. Because those incidents are not similar to the violation at issue here. they could not have put Connlck on notice that specic training was necessary to avoid this constitutional violation .111 C Instead of relying on a pattern of similar Brady violations, Thompson relies '1361 on the \"single- incident" liability that this Court hypothesized in Canton. He contends that the Brady violation in his else was the "obvious" consequence of failing to provide specic Brady training, and that this showing of "obviousness" can substitute for the pattern of violations ordinarily necessary to establish municipal culpability. In Canton, the Court left open the possibility that, "in a narrow range of circumstances,\" a pattern of similar violations might not be necessary to show deliberate indifference. Bryan Cty., supra, at 409, 111 5.21.13.82- The Court posed the hypothetical example of a city that arms its police force with rearms and deploys the armed ofcers into the public to capture eeing felons without training the ofcers in the constitutional limitation on the use of deadly force. mm, W; Given the known frequency with which police attempt to arrest eeing felons and the \"predictability that an ofcer lacking specic tools to handle that situation will violate citizens' rights," the Court theorized that a city's decision not to train the ofcers about constitutional limits on the use of deadly force could reect the city's deliberate indifference to the "highly predictable consequence," namely, violations of constitutional rights. Bryan Cty., supra, at 409, 117 sg. 1382. The Court sought not to foreclose the possibility, however rare. that the unconstitutional consequences of failing to train could be so patently obvious that a city could be liable under 1983 without proof of a pre-existing pattern of violations. Failure to train prosecutors in their Brady obligations does not fall within the narrow range of Canton's hypothesized single-incident liability. The obvious need for specic legal training that was present in the Canton scenario is absent here. Armed police must sometimes make splitsecond decisions with life-or- death consequences. There is no reason to assume that police academy applicants are familiar with the constitutional constraints on the use of deadly force. And, in the absence of training, there is no way for novice ofcers to obtain the legal knowledge they require. Under those circumstances there is an obvious need for some form of training. In stark contrast, legal "[t]raining is what differentiates attorneys from average public employees.\" 578 F.3d, at 304-305 (opinion of Clement. J.). Attorneys are trained in the law and equipped with the tools to interpret and apply legal principles, understand constitutional limits, and exercise legal judgment. Before they may enter the profession and 1362 1363 receive a law license. all attorneys must graduate from law school or pass a substantive examination; attorneys in the vast majority ofjurisdictions must do both. See, 9.9., La. State Bar Assn. (LSBA), Articles of Incorporation, La.Rev.Stat. Ann. 37. ch. 4, App., Art. 14. 7 (1988 West Supp.) (as amended through 1985). These threshold requirements are designed to ensure that all new attorneys have learned how to nd, understand, and apply legal rules. Cf. W 658 4 194 .Qt. 2039 89 L.Ed.2d 657 (1984) (noting that the presumption "that the lawyer is competent to provide the guiding hand that the defendant needs" applies even to '1362 young and inexperienced lawyers in their rst jury trial and even when the case is complex). Nor does professional training end at graduation. Most jurisdictions require attorneys to satisfy continuing-education requirements. See, e.g., LSBA, Articles of Incorporation, Art. 16, Rule 1.1(b) (effective 1987); La. Sup.Ct. Rule XXX (effective 1988). Even those fewjurisdictions that do not impose mandatory continuing-education requirements mandate that attorneys represent their clients competently and encourage attorneys to engage in continuing study and education. See, e.g., Mass. Rule Prof. Conduct 1.1 and comment 6 (West 2006). Before Louisiana adopted continuing-education requirements, it imposed similar general competency requirements on its state bar. LSBA, Articles of Incorporation, Art. 16, EC 1-1, 1-2, DR 6-101 (West 1974) (effective 1971). Attorneys who practice with other attorneys, such as in district attorney's ofces, also train on the job as they learn from more experienced attorneys. For instance, here in the Orleans Parish District Attorney's Ofce. junior prosecutors were trained by senior prosecutors who supervised them as they worked together to prepare cases for trial, and trial chiefs oversaw the preparation of the cases. Senior attorneys also circulated court decisions and instructional memoranda to keep the prosecutors abreast of relevant legal developments. in addition, attorneys in all jurisdictions must satisfy character and tness standards to receive a law license and are personally subject to an ethical regime designed to reinforce the profession's standards. See, e.g., LSBA, Articles of Incorporation, Art. 14, 7 (1985); see generally id., Art. 16 (1971) (Code of Professional Responsibility). Trial lawyers have a "duty to bring to bear such skill and knowledge as will render the trial a reliable adversarial testing process." W U.S. 668 688, 104 S.Ct. 2052 80 L.Ed.2d 674 (1984). Prosecutors have a special "duty to seekjustice, not merely to convict." LSBA, Articles of Incorporation, Art. 16, EC 7-13 (1971); ABA Standards for Criminal Justice 3-1.1(c) (2d ed.1980). Among prosecutors' unique ethical obligations is the duty to produce Brady evidence to the defense. See, e.g., LSBA, Articles of Incorporation, Art. 16, EC 7-13 (1971); ABA Model Rule of Prof. Conduct 3.8(d) (19349151 An attorney '1363 who violates his or her ethical obligations is subject to professional discipline, including sanctions, suspension, and disbarment. See, e.g., LSBA, Articles of Incorporation, Art. 15, 5, 6 (1971); id., Art. 16, DR 1-102; ABA Model Rule of Prof. Conduct 8.4 (1984). In light of this regime of legal training and professional responsibility, recurring constitutional violations are not the "obvious consequence" of failing to provide prosecutors with formal in-house training about how to obey the law. WWW. Prosecutors are not only equipped but are also ethically bound to know what Brady entails and to perform legal research when they are uncertain. A district attorney is entitled to rely on prosecutors' professional training and ethical obligations in the absence of specic reason, such as a pattern of violations, to believe that those tools are insufficient to prevent future constitutional violations in "the usual and recurring situations with 1386, for the Court's conclusion in Bryan County that a pattern of violations is "ordinarily necessary" to which [the prosecutors] must deal." Canton, 489 U.S., at 391, 109 S.Ct. 1197. A licensed attorney demonstrate deliberate indifference for purposes of failure to train, 520 U.S., at 409, 117 S.Ct. 1382. making legal judgments, in his capacity as a prosecutor, about Brady material simply does not present Cf. id., at 406-408, 117 S.Ct. 1382 (explaining why a pattern of violations is ordinarily necessary). But the same "highly predictable" constitutional danger as Canton's untrained officer. cf. post, at 1385-1386 (describing our reliance on Bryan County as "imply[ing]" a new "limitation" on S 1983). As our precedent makes clear, proving that a municipality itself actually caused a constitutional A second significant difference between this case and the example in Canton is the nuance of the violation by failing to train the offending employee presents "difficult problems of proof," and we must allegedly necessary training. The Canton hypothetical assumes that the armed police officers have no adhere to a "stringent standard of fault," lest municipal liability under $ 1983 collapse into respondeat knowledge at all of the constitutional limits on the use of deadly force. But it is undisputed here that the superior. [121 Bryan County, 520 U.S., at 406, 410. 117 S.Ct. 1382; see Canton, 489 U.S., at 391-392. prosecutors in Connick's office were familiar with the general Brady rule. Thompson's complaint 109 S.Ct. 1197. therefore cannot rely on the utter lack of an ability to cope with constitutional situations that underlies the Canton hypothetical, but rather must assert that prosecutors were not trained about particular Brady evidence or the specific scenario related to the violation in his case. That sort of nuance simply 3 cannot support an inference of deliberate indifference here. As the Court said in Canton, "[ijn virtually every instance where a person has had his or her constitutional rights violated by a city employee, a $ The District Court and the Court of Appeals panel erroneously believed that Thompson had proved 1983 plaintiff will be able to point to something the city 'could have done' to prevent the unfortunate deliberate indifference by showing the "obviousness" of a need for additional training. They based this incident." 489 U.S., at 392, 109 S.Ct. 1197 (citing Tuttle, 471 U.S., at 823, 105 S.Ct. 2427 (plurality conclusion on Connick's awareness that (1) prosecutors would confront Brady issues while at the opinion)) district attorney's office; (2) inexperienced prosecutors were expected to understand Brady's requirements; (3) Brady has gray areas that make for difficult choices; and (4) erroneous decisions Thompson suggests that the absence of any formal training sessions about Brady is equivalent to the regarding Brady evidence would result in constitutional violations. 553 F.3d, at 854; App. to Pet. for complete absence of legal training that the Court imagined in Canton. But failure-to-train liability is Cert. 141a, 2005 WL 3541035, *13. This is insufficient. concerned with the substance of the training, not the particular instructional format. The statute does not provide plaintiffs or courts carte blanche to micromanage local governments throughout the United It does not follow that, because Brady has gray areas and some Brady decisions are difficult, States prosecutors will so obviously make wrong decisions that failing to train them amounts to "a decision by the city itself to violate the Constitution." Canton, 489 U.S., at 395, 109 S.Ct. 1197 (O'Connor, J.. We do not assume that prosecutors will always make correct Brady decisions or that guidance concurring in part and dissenting in part). To prove deliberate indifference, Thompson needed to show regarding specific Brady questions would not assist prosecutors. But showing merely that additional that Connick was on notice that, absent additional specified training, it was "highly predictable" that the training would have been helpful in making difficult decisions does not establish municipal liability. " prosecutors in his office would be confounded by those gray areas and make incorrect Brady decisions Pjrov[ing] that an injury or accident could have been avoided if an [employee] had had better or more as a result. In fact, Thompson had to show that it was so predictable that failing to train the 1364 training, sufficient to equip him to avoid the particular injury-causing conduct" will *1364 not suffice. prosecutors amounted to conscious disregard for defendants' Brady rights. See Bryan Cty., 520 U.S., Canton, supra, at 391, 109 S.Ct. 1197. The possibility of single-incident liability that the Court left open at 409, 117 S.Ct. 1382; Canton, supra, at 389, 109 S.Ct. 1197. He did not do so. in Canton is not this case. [10] III 2 The role of a prosecutor is to see that justice is done. Berger v. United States. 295 U.S. 78, 88, 55 S.Ct. The dissent rejects our holding that Canton's hypothesized single-incident liability does not, as a legal 629, 79 L.Ed. 1314 (1935). "It is as much [a prosecutor's] duty to refrain from improper methods matter, encompass failure to train prosecutors in their Brady obligation. It would instead apply the calculated to produce a wrongful conviction as it is to use every legitimate means to bring about a just Canton hypothetical to this case, and thus devotes almost all of its opinion to explaining why the 1366 one." Ibid. By their own admission, the prosecutors who tried Thompson's armed robbery evidence supports liability under that theory.But the dissent's attempt to address our holding-by failed to carry out that responsibility. But the only issue before us is whether Connick, as t pointing out that not all prosecutors will necessarily have enrolled in criminal procedure class-misses policymaker for the district attorney's office, was deliberately indifferent to the need to train the point. See post, at 1385-1386. The reason why the Canton hypothetical is inapplicable is that attorneys under his authority attorneys, unlike police officers, are equipped with the tools to find, interpret, and apply legal principles. We conclude that this case does not fall within the narrow range of "single-incident" liability By the end of its opinion, however, the dissent finally reveals that its real disagreement is not with our hypothesized in Canton as a possible exception to the pattern of violations necessary to prove 1365 holding today, but with this Court's precedent. The dissent *1365 does not see "any reason," post, at deliberate indifference in $ 1983 actions alleging failure to train. The District Court should have grantedConnick judgment as a matter of law on the failure-to-train claim because Thompson did not prove a pattern of similar violations that would "establish that the 'policy of inaction' [was] the functional equivalent of a decision by the city itself to violate the Constitution." Qantgn, supra at as; 19$ .t 11 7 i ' f ' n r The judgment of the United States Court of Appeals for the Fifth Circuit is reversed. It is so ordered. Justice SCALIA, with whom Justice ALITO joins, concurring. | join the Court's opinion in full. i write separately only to address several aspects of the dissent. 1. The dissent's lengthy excavation of the trial record is a puzzling exertion. The question presented for our review is whether a municipality is liable for a single Brady violation by one of its prosecutors, even though no pattern or practice of prior violations put the municipality on notice of a need for specic training that would have prevented it. See Win 215 (19$). That question is a legal one: whether a Brady violation presents one of those rare circumstances we hypothesized in Canton's footnote 10, in which the need for training in constitutional requirements is so obvious ex ante that the munid'pality's failure to provide that training amounts to deliberate indifference to constitutional violations. See nlgn v. Harris 4 LJ-- 7 3&9 n. 19 192 W- The dissent defers consideration of this question until page 1382 of its opinion. It rst devotes considerable space to allegations that Connick's prosecutors misunderstood Bradywhen asked about it at trial, see past, at 1378-1379 (opinion of GINSBURG, J.), and to supposed gaps in the Brady guidance provided by Connlck's ofce to prosecutors, including deciencies (unrelated to the specic Brady violation at issue in this case) in a policy manual published by Connick's ofce three years after Thompson's trial, see post, at 1379-1380. None of that is relevant. Thompson's failure-to-train theory at trial was not based on a pervasive culture of indifference to Brady, but rather on the inevitability of mistakes over enough iterations of criminal trials. The District Court instructed the jury it could nd Connick deliberately indifferent if: \"First: The District Attorney was certain that prosecutors would confront the situation where they would have to decide which evidence was required by the constitution to be provided to an accused[;] \"Second: The situation involved a difcult choice, or one that prosecutors had a history of mishandling, such that additional training, supervision, or monitoring was clearly needed[; and] \"Third: The wrong choice by a prosecutor in that situation will frequently cause a deprivation of an accused's constitutional rights." App. 828. 1367 '1367 That theory of deliberate indifference would repeal the law of Monell'll in favor of the Law of Large Numbers. Brady mistakes are inevitable. So are all species of error routinely confronted by 1368 prosecutors: authorizing a bad warrant; losing a Batsonm claim; crossing the line in closing argument; or eliciting hearsay that violates the Confrontation Clause. Nevertheless, we do not have "de facto respondeat superior liability," nt n 4 . 11 7 for each such violation under the rubric of failure-to-train simply because the municipality does not have a professional educational program covering the specic violation in sufcient depthm Were Thompson's theory the law, there would have been no need for Canton's footnote to conne its hypothetical to the extreme circumstance of arming police ofcers with guns without telling them about the constitutional limitations upon shooting eeing felons; the District Court's instructions cover every recurring situation in which citizens' rights can be violated. That result cannot be squared with our admonition that failure-to-train liability is available only in "limited circumstances,\" id., at 387, W, and that a pattern of constitutional violations is "ordinarily necessary to establish municipal culpability and causation," ag of mm' 9f Eugen Qty. WWW. These restrictions are indispensable because without them, "failure to train" would become a talismanic incantation producing municipal liability "[i]n virtually every instance where a person has had his or her constitutional rights violated by a city employee\"which is what Mane/I rejects. WWW. Worse, it would \"engage the federal courts in an endless exercise of second-guessing municipal employee-training programs," thereby diminishing the autonomy of state and local governments. (bid. 2. Perhaps for that reason, the dissent does not seriously contend that Thompson's theory of recovery was proper. Rather, it accuses Connlck of acquiescing in that theory at trial. See post, at 1383. The accusation is false. Connick's central claim was and is that failure-to-train liability for a Brady violation cannot be premised on a single incident, but requires a pattern or practice of previous violations. He pressed that argument at the summaryjudgment stage but was rebuffed. At trial, when Connick offered a jury instruction to the same effect, the trial judge effectively told him to stop bringing up the subject: '[Connick's counsel]: Also, as part of that denition in that same location, Your Honor, we would like to include language that says that deliberate indifference to training requires a pattern of similar violations and proof of deliberate indifference requires more than a single isolated act. '[Thompson's counsel]: That's not the law, Your Honor. '1368 \"THE COURT: No, I'm not giving that. That was in your motion for summary judgment that l denied." Tr. 1013. Nothing more is required to preserve a claim of error. See Fed. Rule Civ. Proc. 51 (d)(1)(B 3. But in any event, to recover from a municipality under 42 U.S.C. 1983, a plaintiff must "rigorous" standard of causation, W; he must "d: direct causal link between the municipal action and the deprivation of federal rights.\" ld., a .Qt. 12. Thompson cannot meet that standard. The withholding of evidence in his case was almost certainly caused not by a failure to give prosecutors specic training, but by miscreant prosecutor Gerry 1 369 Deegan's willful suppression of evidence he believed to be exculpatory, in an effort to railroad Thompson. According to Deegan's colleague Michael Riehlmann, in 1994 Deegan confessed to him in the same conversation in which Deegan revealed he had only a few months to live that he had "suppressed blood evidence in the armed robbery trial of John Thompson that in some way exculpated the defendant.\" App. 367; see also id., at 362 ("[Deegan] told me . . .that he had failed to inform the defense of exculpatory information"). l have no reason to disbelieve that account, particularly since Riehlmann's testimony hardly paints a attering picture of himself: Riehlmann kept silent about Deegan's misconduct for another ve years, as a result of which he incurred professional sanctions. See WW. And if Riehlmann's story is true, then the "moving force," Bryan Cty, supra, at 404, W (internal quotation marks omitted), behind the suppression of evidence was Deegan, not a failure of continuing legal education. 4. The dissent suspends disbelief about this, insisting that with proper Brady training, "surely at least one" of the prosecutors in Thompson's trial would have turned over the lab report and blood swatch. Post, at 1380. But training must consist of more than mere broad enoomiums of Brady: We have made clear that "the identied deciency in a city's training program [must be] closely related to the ultimate injury." WM, 199 5 Qt 1191. So even indulging the dissent's assumption that Thompson's prosecutors failed to disclose the lab report in good faithin a way that could be prevented by trainingwhat sort of training would have prevented the good-faith nondisclosure of a blood report not known to be exculpatory/t Perhaps a better question to ask is what legally accurate training would have prevented it. The dissent's suggestion is to instruct prosecutors to ignore the portion of Brady limiting prosecutors' disclosure obligations to evidence that is "favorable to an accused," 373 U.S. at 87 83 S.Ct. 1194. Instead, the dissent proposes that "Connlck could have communicated to Orleans Parish prosecutors, in no uncertain terms, '1369 that, 'mf you have physical evidence that, if tested, can establish the innocence of the person who is charged, you have to turn it over.\" Post, at 1380, n. 13 (quoting Tr. of Oral Arg. 34). Though labeled a training suggestion, the dissent's proposal is better described as a sub silentio expansion of the substantive law of Brady. If any of our cases establishes such an obligation, | have never read it, and the dissent does not cite it.ll Since Thompson's trial, however, we have decided a case that appears to sayjust the opposite of the training the dissent would require: In Arizona v. Youngblood 488 U.S. 51 58 109 S.Ct. 333 102 L.Ed.2d 281 Haj we held that "unless a criminal defendant can show bad faith on the part of the police, failure to preserve potentially useful evidence does not constitute a denial of due process of law." We acknowledged that "Brady. . . makes the good or bad faith of the State irrelevant when the State fails to disclose to the defendant material exculpatory evidence," but concluded that "the Due Process Clause requires a different result when we deal with the failure of the State to preserve evidentiary material of which no more can be said than that it could have been subjected to tests, the results of which might have exonerated the defendant.\" Id, at 57, 109 S.Ct. 333. Perhaps one day we will recognize a distinction between good-faith failures to preserve from destruction evidence whose inoulpatory or exculpatory character is unknown, and good-faith failures to turn such evidence over to the defense. But until we do so, a failure to train prosecutors to obsen/e that distinction cannot constitute deliberate indifference. 1370 5. By now the reader has doubtless guessed the best-kept secret of this case: There was probably no Brady violation at allexcept for Deegan's (which, since it was a bad-faith, knowing violation, could not possibly be attributed to lack of training).l1 The dissent surely knows this, which is why it leans heavily on the fact that Connick conceded that Brady was violated. I can honor that concession in my analysis of the case because even if it extends beyond Deegan's deliberate actions, it remains irrelevant to Connick's training obligations. For any Brady violation apart from Deegan's was surely on the very frontier of our Brady jurisprudence; Connlck could not possibly have been on notice decades ago that he was required to instruct his prosecutors to respect a right to untested evidence that we had not (and still have not) recognized. As a consequence, even if I accepted the dissent's conclusion that failure-to- train liability '1370 could be premised on a single Brady error, I could not agree that the lack of an accurate training regimen caused the violation Connick has conceded. Justice GINSBURG, with whom Justice BREYER, Justice SOTOMAYOR, and Justice KAGAN join, dissenting. In m V. Maryland 373 U.S. 33 87 83 S.Ct. 1194 10 L.Ed.2d 215 (19j this Court held that due process requires the prosecution to turn over evidence favorable to the accused and material to his guilt or punishment. That obligation, the parties have stipulated, was dishonored in this case; consequently, John Thompson spent 18 years in prison, 14 of them isolated on death row, before the truth came to light: He was innocent of the charge of attempted armed robbery, and his subsequent trial on a murder charge, by prosewtorial design, was fundamentally unfair. The Court holds that the Orleans Parish District Attorney's Ofce (District Attorney's Ofce or Ofce) cannot be held liable, in a civil rights action under 42 U.S.C. 1983, for the grave injustice Thompson suffered. That is so, the Court tells us, because Thompson has shown only an aberrant Brady violation, not a routine practice of giving short shrift to Bradys requirements. The evidence presented to the jury that awarded compensation to Thompson, however, points distinctly away from the Court's assessment. As the trial record in the 1983 action reveals, the conceded, long-concealed prosecutorial transgressions were neither isolated nor atypical. From the top down, the evidence showed, members of the District Attorney's Ofce, including the District Attorney himself, misperceived Brady's compass and therefore inadequately attended to their disclosure obligations. Throughout the pretrial and trial proceedings against Thompson, the team of four engaged in prosecuting him for armed robbery and murder hid from the defense and the court exculpatory information Thompson requested and had a constitutional right to receive. The prosecutors did so despite multiple opportunities, spanning nearly two decades, to set the record straight. Based on the prosecutors' conduct relating to Thompson's trials, a fact trier could reasonably conclude that inattenticn to Brady was standard operating procedure at the District Attorne What happened here, the Court's opinion obscures, was no momentary oversight, no sing a lone officer's misconduct. Instead, the evidence demonstrated that misperception and dI Brady's disclosure requirements were pervasive in Orleans Parish. That evidence, I would established persistent, deliberately indifferent conduct for which the District Attorney's OfL- responsibility under 1983