Can a governmental entity be held liable for failing to adequately supervise or train its employees?

MultiRegion, United States of America

The following excerpt is from Ting v. U.S., 927 F.2d 1504 (9th Cir. 1991):

It is well-established that a governmental officer may be held liable for damages for constitutional wrongs engendered by his failure to adequately supervise or train his subordinates. Bergquist v. County of Cochise, 806 F.2d 1364, 1369-70 (9th Cir.1986). Similarly, a governmental entity may also be liable for due process violations which result from its failure to train its employees. Id. However, the inadequacy of police training may serve as a basis for liability under section 1983 or Bivens "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 v. Harris, 489 U.S. 378, 388, 109 S.Ct. 1197, 1204, 103 L.Ed.2d 412 (1989).

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