The following excerpt is from Howard v. Cnty. of Tulare, Case No. 1:16-cv-00076-SAB (E.D. Cal. 2016):
A section 1983 plaintiff alleging a policy of failure to train officers must show: (1) he/she was deprived of a constitutional right; (2) the local government entity had a training policy that amounts to deliberate indifference to constitutional rights of persons with whom its officers are likely to come into contact; and (3) his/her constitutional injury would have been avoided had the government entity properly trained those officers. Blankenhorn v. City of Orange, 485 F.3d 463, 484 (9th Cir. 2007).
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