The following excerpt is from Smith-Downs v. City of Stockton, No. 2:10-cv-02495-MCE-GGH (E.D. Cal. 2012):
A plaintiff alleging a failure to train must show that "(1) he was deprived of a constitutional right; (2) the [municipality] had a training policy that 'amounts to deliberate indifference to the [constitutional] rights of the persons' with whom [its employees] are likely to come into contact'; and (3) his constitutional injury would have been avoided had the
[municipality] properly trained those officers." Blankenhorn v. City of Orange, 485 F.3d 463, 484 (9th Cir. 2007).
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