Brief Bank II: indexed by issue

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Civil rights [ 56 ]

PLAINTIFF’S RESPONSE TO DEFENDANT CITY OF ALBUQUERQUE’S 12(B)(6) MOTION

TO DISMISS PLAINTIFF’S SECOND MUNICIPAL LIABILITY CLAIM

A municipality may be liable for a policy or custom that causes deprivation of

constitutional rights. Bryan County of Brown, 520 U.S. 397, 403 (1997). An

unconstitutional custom is one that may have no formal approval, but is so widespread

that is has “the force of law”. Id. at 404; Canon v. City and County of Denver, 998 F.

2d 867, 877 (10th Cir. 1993). A municipality may be held liable for a “continued

adherence to an approach” that fails to prevent tortuous conduct. Id. at 407. In

addition, a failure to train claim may support municipal liability based upon one violation

of federal rights if plaintiff shows that the municipality “has failed to train it employees to

handle recurring situations presenting an obvious potential for such a violation”. Id. at

409; citing, City of Canton v. Harris, 489 U.S. 378 (1989).

by Kennedy & Oliver, P.C.

ELIAS GONZALES v. THE CITY OF ALBUQUERQUE D.N.M. CIV 03-1150 ( 2004 )

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