What is the test for establishing that a municipal employee violated a plaintiff's federal rights?

"That a plaintiff has suffered a deprivation of federal rights at the hands of a municipal employee will not alone permit an inference of municipal culpability and causation; the plaintiff will simply have shown that the employee acted culpably." Bd of the County Commissioners of Bryan County, Okla v. Brown 520 U.S. 397, 406-07 (1997) (emphasis in original). "[A] plaintiff seeking to establish that a facially lawful municipal action has led an employee to violate a plaintiff's rights

Page 6