Can a "failure to train or supervise" theory be the basis for a supervisor's liability under Section 1983?

A "failure to train" or "failure to supervise" theory can be the basis for a supervisor's liability under 1983 in only limited circumstances, such as where the failure amounts to deliberate indifference. See City of Canton v. Harris, 489 U.S. 378, 387-90, 109 S.Ct. 1197, 103 L.Ed.2d 412 (1989) (A failure to train or supervise may satisfy this criteria if, "in light of the duties assigned to specific officers or employees[,] the need for more or different training is so obvious, and the inadequacy so likely to result in the violation of constitutional rights, that

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