> Most of the big payouts have to come from the cities.

In other words, from the victimized populace.

I think a cop who steals seized evidence should be personally liable to the person they stole from.

(…and I'd note "v. City of Wichita" is clearly responsive to your question.)

I would probably say that both the city and the cop should, independently, be liable. Given the position of authority the city provides, it is ultimately responsible to hire and properly train people who will use that authority well, while the individual is also responsible for their own actions.