The following excerpt is from Blanco v. Cnty. of Kings, 142 F.Supp.3d 986 (E.D. Cal. 2015):
Id. (quoting City of Canton v. Harris, 489 U.S. 378, 388, 109 S.Ct. 1197, 103 L.Ed.2d 412 (1989) ). " [D]eliberate indifference is a stringent standard of fault, requiring proof that a municipal actor disregarded a known or obvious consequence of his action." Bryan County, 520 U.S. at 410, 117 S.Ct. 1382. "A pattern of similar constitutional violations by untrained employees is ordinarily necessary to demonstrate deliberate indifference for purposes of failure to train." Connick, 131 S.Ct. at 1360 (internal citations omitted); Canton, 489 U.S. at 395, 109 S.Ct. 1197. To demonstrate that the City is "deliberately indifferent," Plaintiff must show that the City's policymakers were on "actual or constructive notice that a particular omission in their training program causes employees to violate citizens' constitutional rights." Connick, 131 S.Ct. at 1360.
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