What is the standard for supervisory liability for excessive force in the Fourth Amendment?

MultiRegion, United States of America

The following excerpt is from YY.. v. United States, CASE NO. 13cv1417-WQH-BGS (S.D. Cal. 2015):

Prior to May, 18, 2009, the date Ashcroft v. Iqbal was decided, the governing standard for supervisory liability for Fourth Amendment excessive force was stated as follows:

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