In the public workplace of criminal justice organization employees, there are numerous court cases that either hold an employee(s), the criminal justice organization or both accountable for intentional and sometimes unintentional deprivations of a citizen's constitution rights in the form of a civil tort. There is a specific U.S. Supreme Court case that now will no longer allow the acceptance of the excuse of, "I didn't know," in that the justices indicated that in some cases there is a 'duty to train employees' to avoid such violations. Many times this case is referred to as the one that 'opened the litigation door' for the failure to reasonable train an employee. That case is