The following excerpt is from Hoffman v. Lassen Adult Det. Facility, No. 2: 15-cv-1558 JAM KJN P (E.D. Cal. 2017):
conscious or deliberate disregardto the constitutional rights of its inhabitants. City of Canton v. Harris, 489 U.S. 378, 392 (1989); Flores v. County of Los Angeles, 758 F.3d 1154, 1158 (9th Cir. 2014). "A pattern of similar constitutional violations by untrained employees is 'ordinarily necessary' to demonstrate deliberate indifference for purposes of failure to train ... Without notice that a course of training is deficient in a particular respect, decisionmakers can hardly be said to have deliberately chosen a training program that will cause violations of constitutional rights." Connick v. Thompson, 563 U.S. 51, 62 (2011).
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