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First Circuit Review 2006

42 U.S.C. § 1983 imposes civil liability on municipalities when a policy, or the execution of a policy, is found to be unconstitutional.  The United States Supreme Court has developed a stringent set of guidelines for determining municipality liability that excludes respondeat superior recovery.  In Young v. City of Providence, the First Circuit considered whether the Providence Police Department’s training program met the strict standards of review for municipality liability so as for the city to be rightfully granted summary judgment.  The court concluded that a jury could find that the Providence Police Department had an inadequate training program for its “always armed/always on duty” policy, and that the deficient training resulted in the death of an off-duty officer. . . .