The following excerpt is from Horton v. Cnty. of San Diego, Case No.: 21-cv-00400-H-BGS (S.D. Cal. 2021):
. . the need to train officers in the constitutional limitations on the use of deadly force can be said to be "so obvious," that failure to do so could properly be characterized as deliberate indifference to constitutional rights.'" Id. (quoting City of Canton, Ohio v. Harris, 489 U.S. 378, 390 n.10 (1989)).
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