The following excerpt is from Rojas v. Johnson, Case No.: 3:17-cv-01287-JAH-JMA (S.D. Cal. 2017):
In addition, a municipality's failure to train its employees in a relevant respect must amount to "deliberate indifference to the rights of persons with whom the [untrained employees] come into contact." Connick v. Thompson, 563 U.S. 51, 60 (2011) (citing Canton, 489 U.S. at 388). "Only then "can such a shortcoming be properly thought of as a city 'policy or custom' that is actionable under 1983." Id. at 61 (citing Canton, 489 U.S. at 389).
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