What is the standard for a failure to train an employee?

The standard is an exacting one. Applying a less demanding standard in failure-to-train cases would circumvent the rule against respondeat superior liability of municipalities. Id. at 392. "[M]unicipal liability under 1983 attaches whereand only wherea deliberate choice to follow a course of action is made from among various alternatives by [the relevant] officials." Penbauer v. City of Cincinnati, 475 U.S. 469, 483 (1986). To state a cognizable claim, a plaintiff must allege specific facts supporting the conclusion that the municipal entity had actual or constructive notice that their training program (or lack thereof) resulted in their employees' violating citizens' federal constitutional rights and that the municipality made a deliberate choice to train (or not to train) its employees as a deliberate decision drawn from its consideration of various alternatives.

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