The following excerpt is from Rivera v. Davey, Case No. 1:16-cv-01817-AWI-BAM (PC) (E.D. Cal. 2020):
training is obvious, and the inadequacy so likely to result in violations of constitutional rights, that the policy-makers ... can reasonably be said to have been deliberately indifferent to the need." (citation and internal quotation marks omitted)). "A pattern of similar constitutional violations by untrained employees is 'ordinarily necessary' to demonstrate deliberate indifference for purposes of failure to train." Connick v. Thompson, 563 U.S. 51, 61 (2011) (citation omitted).
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