What is the test for deliberate indifference by an employer to an employee who has not been properly trained in the profession?
MultiRegion, United States of America
The following excerpt is from Snyder v. Robertson, Case No. 1:18-cv-01063-BAM (PC) (E.D. Cal. 2020):
Ordinarily, a single constitutional violation by an untrained employee is insufficient to demonstrate deliberate indifference for purposes of failure to train. Connick v. Thompson, 563 U.S. 51, 62 (2011). Instead, a pattern of similar constitutional violations by untrained employees is "ordinarily necessary" to demonstrate deliberate indifference for purposes of failure to train. Id.
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