The following excerpt is from Hawkins v. San Diego Cnty., Case No.: 3:20-cv-2200-WQH-KSC (S.D. Cal. 2021):
allege "more than negligence but less than subjective intentsomething akin to reckless disregard." Id. The "'mere lack of due care by a [county] official does not deprive an individual of life, liberty, or property under the Fourteenth Amendment." Id. (quoting Daniels v. Williams, 474 U.S. 327, 330-31 (1986)).
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