The following excerpt is from Quinn v. Fresno Cnty. Sheriff, Case No. 1:10-cv-01617 LJO BAM (E.D. Cal. 2012):
Spell v. McDaniel, 824 F.2d 1380, 1387 (4th Cir. 1987) ("Custom and usage, in the sense of persistent and widespread . . . practices by municipal agents and employees, may be attributed to a municipality when the duration and frequency of the practices warrants a finding of either actual or constructive knowledge by the [municipality] . . . that the practices have become customary among its employees.") (internal quotation marks omitted).
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