The following excerpt is from Mouwakeh v. Cnty. of San Diego, Case No.: 15-CV-2372 W (KSC) (S.D. Cal. 2016):
amount to a policy of 'deliberate indifference,' if the need to train was obvious and the failure to do so made a violation of constitutional rights likely." Id. (quoting City of Canton v. Harris, 489 U.S. 378, 390 (1989).
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