The following excerpt is from And v. Cnty. of San Diego, Case No.: 3:18-cv-0246-CAB-(JMA) (S.D. Cal. 2018):
A local government body may be held liable for its failure to train employees or failure to provide a different kinds of training if the failure causes a constitutional violation, and the failure amounts to deliberate indifference to the rights of individuals who come into contact with the employees. See City of Canton v. Harris, 489 U.S. 378, 388-89 (1989) ("[I]t may happen that 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 the policymakers of the city can reasonably be said to have been deliberately indifferent to the need. In that event, the failure to provide proper training may fairly be said to represent a policy for which the city is responsible, and for which the city may be held liable if it actually causes injury").
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