In the case City of Oklahoma City v. Tuttle, 1984, the U.S. Supreme Court examined whether a single incident of police misconduct could be used as evidence to prove that a city had an existing policy that led to violations of civil rights under Section 1983. The case arose from an incident where James Tuttle was shot and killed by Officer Stuckey during an arrest attempt at a bar in Oklahoma City. His widow sued both Stuckey and the city for violating her husband's constitutional rights due to inadequate training provided by the city to its officers on use-of-force policies. The court ruled in favor of Oklahoma City with a majority opinion stating that proof of one isolated incident is not sufficient enough evidence to establish municipal liability unless it can be proven beyond doubt that this action was taken or sanctioned by those who were responsible for making final policy decisions regarding law enforcement practices within the municipality.

In the dissenting opinion for City of Oklahoma City v. Tuttle, Justice Brennan argued that the majority's decision was incorrect in requiring plaintiffs to prove a city's policy or custom directly caused their injury under Section 1983. He believed this standard was too high and not supported by prior case law or legislative history. Instead, he suggested that it should be enough if a plaintiff can show an official policy tolerates constitutional violations by its police officers, even without direct causation evidence. Furthermore, he disagreed with the majority’s view on jury instructions and held that they were adequate in this case as they allowed jurors to infer from circumstantial evidence whether there existed an official policy leading to constitutional violation. Finally, he criticized the court for deciding issues not presented at trial or addressed by lower courts.