Can a city be held liable for failing to properly train its police officers?

MultiRegion, United States of America

The following excerpt is from Hahn v. City of Kenya, Case No. 15-cv-2007 DMS (BGS) (S.D. Cal. 2017):

"[T]he inadequacy of police training may serve as the basis for 1983 liability only where the failure to train amounts to deliberate indifference to the rights of persons with whom the police come into contact." City of Canton, Ohio v. Harris, 489 U.S. 378, 388 (1989). A plaintiff seeking to hold a city liable based on an alleged failure to train its police officers must show that "(1) he was deprived of a constitutional right, (2) the City had a training policy that amounts to deliberate indifference to the [constitutional] rights of the persons with whom [its police officers] are likely to come into contact; and (3) his constitutional injury would have been avoided had the City properly trained those officers." Blankenhorn, 485 F.3d at 484 (citing Lee v. City of L.A., 250 F.3d 668, 681 (9th Cir. 2001)) (internal quotation marks omitted).

The City argues it is entitled to summary judgment because its training

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