The following excerpt is from Torbert v. Gore, Case No.: 14cv2911 BEN (NLS) (S.D. Cal. 2016):
acts of its policymaking officials, and practices so persistent and widespread as to practically have the force of law." Id. Such a policy can be shown where a municipality's failure to train its employees in a relevant respect amounts to "deliberate indifference to the rights of persons with whom the [untrained employees] come into contact." City of Canton v. Harris, 489 U.S. 378, 388 (1989). When the allegation includes a failure to train employees, "[a] pattern of similar constitutional violations by untrained employees is 'ordinarily necessary' to demonstrate deliberate indifference." Bd. Of the County Comm'Rs v. Brown, 520 U.S. 397, 409 (1997). But "[w]ithout notice that a course of training is deficient in a particular respect, decision makers can hardly be said to have deliberately chosen a training program that will cause violations of constitutional rights." Connick, 563 U.S. at 62. Further, the alleged incidents must constitute actual Constitutional violations. Id.
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