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Abstract: 

To establish deliberate indifference in training, the claimant must show policymakers are on notice that a particular omission in training causes employees to violate the rights of others. A seriously mentally ill detainee is beaten savagely when he becomes agitatated about a delay in receiving needed medication. A jury finds the three officers involved guilty of inflicting cruel and unusual punishment. But was inadequate training at fault? In Johnson v. Dixon (11th Cir. 2016), the court finds that burden is not met and creates a more stringent standard than is found in other jurisdictions.

Keywords: Duty to train

Affiliations:  1: Executive Editor.