ABSTRACT
OVERVIEW Since the United States Supreme Court decision in City of Canton v. Harris (1989), the plaintiff in the majority of civil lawsuits cites as a secondary claim that the errant officer was inadequately trained ( Box 7.1 ). Several scholars estimate that actions for failure to train and failure to supervise are the two most common types of claims brought against police administrators ( Barrineau, 1994; Kappeler, 1997; del Carmen, 1991; Staff, 1990 ). Although tremendous strides have been made in mandating pre-service police training throughout the United States and the number of hours of in-service training for veteran officers is increasing ( Flink, 1997 ), failure-totrain allegations are still a concern for the police administrator.
