What is the legal test for a municipality to be held liable for failing to train its employees in the relevant respect of civil rights?

MultiRegion, United States of America

The following excerpt is from Gonzalez v. Alva, CASE NO: 11-CV-2846 W (WVG) (S.D. Cal. 2013):

For the purposes of 1983, a municipality's failure to train its employees in a relevant respect must amount to "deliberate indifference to the rights of persons with whom the [untrained employees] come into contact." Connick 131 S.Ct. at 1359 (citing Canton, 489 U.S. at 388). Deliberate indifference is "a stringent standard of fault, requiring proof that a municipal actor disregarded a known or obvious consequence of his action." Bryan County, 520 U.S. at 410; see also Price v. Sery, 513 F.3d 962 (9th Cir. 2008) (requiring plaintiffs to "demonstrate a conscious or deliberate choice on the part of the municipality in order to prevail on a failure to train claim." (internal quotations omitted)). "Thus, when city policymakers are on actual or constructive notice that a particular omission in their training program causes city employees to violate citizens' constitutional rights, the city may be deemed deliberately indifferent if the policy makers choose to retain that program." Connick, 131 S.Ct. at 1360 (citing Bryan County, 520 U.S. at 410).

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