“We agree that, absent more evidence of supervisory indifference, such as acquiescence in a prior pattern of conduct, a policy could not ordinarily be inferred from a single incident of illegality such as a first arrest without probable cause or with excessive use of force.... However, a single, unusually brutal or egregious beating administered by a group of municipal employees may be sufficiently out of the ordinary to warrant an inference that it was attributable to inadequate training or supervision amounting to deliberate indifference or ‘gross negligence’ *601 on the part of the officials in charge.”
“The District Court was correct in noting that a mere failure by the county to supervise its employees would not be sufficient to hold it liable under s 1983. However, the county could be held liable if the failure to supervise or the lack of a proper training program was so severe as to reach the level of ‘gross negligence’ or ‘deliberate indifference’ to the deprivation of the plaintiff's constitutional rights.”
“Since under Monell, a local body is a ‘person’ for the purposes of s 1983, we assume that the same definition of ‘person’ would apply to s 1985, which allows damages whenever two or more ‘persons' conspire to violate the civil rights of another. Again the county could not be held liable on a respondeat superior theory. However, if Owens' amended complaint alleges an official custom or policy of the county, relating to failure to train or to other matters stemming from or resulting in a conspiracy implicating the county itself, a s 1985 claim will lie.”
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