What is the test for establishing municipal liability for failing to provide adequate police training?

A plaintiff may also establish municipal liability by establishing that the constitutional violation was caused by a failure to train employees sufficiently. See Price v. Sery, 513 F.3d 962, 973 (9th Cir. 2008). That showing depends on the following three elements: (1) "the existing training program" must be inadequate "in relation to the tasks the particular officers must perform"; (2) the officials must have been deliberately indifferent "to the rights of

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persons with whom the police come into contact"; and (3) the inadequacy of the training "must be shown to have 'actually caused' the deprivation of the alleged constitutional right." Merritt v. Cnty. of Los Angeles, 875 F.2d 765, 770 (9th Cir. 1989) (internal citations and quotation marks omitted).