The following excerpt is from Jeffes, Keenan, et al. v. Barnes, 208 F.3d 49 (2nd Cir. 1998):
Further, municipal liability may be premised on the municipality's failure to train its employees "where that ... failure to train reflects deliberate indifference to ... constitutional rights." City of Canton v. Harris, 489 U.S. at 392. Proof of deliberate indifference is a sine qua non for the imposition of liability on this basis. See id. at 389 ("Only where a municipality's failure to train its employees in a relevant respect evidences a 'deliberate indifference' to the rights of its inhabitants
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