The following excerpt is from Means v. Santa Clara County, 894 F.2d 409 (9th Cir. 1990):
436 U.S. at 694; see also Gibson v. United States, 781 F.2d 1334, 1337 (9th Cir.1986), cert. denied, 479 U.S. 1054 (1987). To show that the injuries she allegedly suffered are part of an official policy or pattern, appellant cited in her complaint instances of county employees calling her such names as "Miss Constitution" and "constitutionalist bitch" and injuries which she allegedly suffered while being detained in the county jail. 1 The latter included one incident where county officials threatened to use force after appellant refused to be fingerprinted, as well as numerous complaints about the lack of amenities, the noise level, and the nature of the individuals with whom she was housed.
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