Howard v. City of Columbus

I concur in the result reached in Divisions 1, 2 (a), 3, 4, and 5 of the majority, but I do not agree with all that is said in those divisions. Because I believe that they contain much that is not necessary to the analysis, I cannot concur fully and must concur in the judgment only as to those divisions.

I must respectfully dissent, however, to Division 2 (b) of the opinion. The majority opinion declares, with respect to Sheriff Hodge, that “the requirements of supervision, including of adequate training and enforcement of all policies, practices, and protocol, are ministerial in nature.” But…