Holmes v. Sheahan’s Empirical Analysis

Citation profile

17 federal appellate · 2 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 43 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Holmes’ claims then, sound in inaction— that is, the County’s failure to institute the policies and procedures necessary to ensure that prison inmates receive, appropriate medical care. We have previously held that deliberate indifference to inmates’ medical needs may indeed be demonstrated by proving “that there are such systemic and gross deficiencies in staffing, facilities, equipment, or procedures that the inmate population is effectively denied access to adequate medical care.” Benson [v. Cady ], 761 F.2d [335] at 341 [7th Cir. 1985] (quoting Wellman, 715 F.2d at 272 ). The County’s failure to train its employees is similarly actionable under a deliberate indifference standard. In making failure-to-train claims, plaintiffs’ must establish that a municipality’s training program is inadequate, and that “such inadequate training can justifiably be said to represent ‘city policy’ ”. Canton v. Harris, 489 U.S. 378 , [381] 109 S.Ct. 1197, 1201 , 103 L.Ed.2d 412 (1988). The latter holds true when “the need for more or different training is so obvious, and the inadequacy so likely to result in the violation of constitutional rights, that the policymakers of the city can reasonably be said to have been deliberately indifferent to the need.” Id.”

   1 later decision quote this exact passage · from the majority
   e.g. 824 F. Supp. 1291 - Rubeck v. Sheriff of Wabash County

2. “Case law recognizes three ways in which a municipality’s policy can violate an individual’s civil rights: “(1) an express policy that, when enforced, causes a constitutional deprivation; (2) ‘a widespread practice that, although not authorized by written law or express municipal policy, is so permanent and well settled as to constitute a “custom or usage” with the force of law5; or (3) an allegation that the constitutional injury was caused by a person with ‘final policymaking authority.’ ””

   1 later decision quote this exact passage · from the majority
   e.g. Harrell v. Sheahan

3. “claims, plaintiffs must establish that a municipality's training program is inadequate and that”

   1 later decision quote this exact passage · from the majority
   e.g. Lake County Juvenile Court v. Swanson