Can a plaintiff establish liability against a municipality by showing the failure to train its employees?

A plaintiff can establish 1983 liability against a municipality by showing the failure to train its employees, but only "where the failure to train amounts to deliberate indifference to the rights of persons with whom the [employee] come into contact." City of Canton, 489 U.S. at 388. "Only where a municipality's failure to train its employees in a relevant respect evidences a 'deliberate indifference' to the rights of its inhabitants can such a shortcoming be properly thought of as a city 'policy or custom' that is actionable under 1983." Id. The plaintiff "must demonstrate a 'conscious' or 'deliberate' choice on the part of a municipality in order to prevail on a failure to train claim." Price v. Sery, 513 F.3d 962, 973 (9th Cir. 2008).

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