Is a municipality's failure to train its police officers a policy of deliberate indifference?

In limited circumstances, a municipality's failure to train its officers may amount to a policy of deliberate indifference. See Price v. Sery, 513 F.3d 962, 973 (9th Cir. 2008). To state a claim for failure to train, a plaintiff must show (1) "the existing training program" is inadequate "in relation to the tasks the particular officers must perform"; (2) the officials have been deliberately indifferent "to the rights of persons with whom the police come into contact"; and (3) the inadequacy of the training "actually caused the constitutional deprivation at issue." Merritt v. Cnty. of L.A., 875 F.2d 765, 770 (9th Cir. 1989) (internal citations and quotation marks omitted).

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