Marvin L. Johnson v. Keith A. Dixon, Jr., 666 F. App'x 828

Johnson, an inmate with bipolar disorder, was beaten by Officer Dixon while two other officers watched; Dixon later returned and used a stun gun; Johnson received no timely medical care.
The three officers were found by a jury to have violated Johnson’s Eighth Amendment rights; Dixon resigned and faced criminal and internal discipline.
Johnson sued the officers individually and sued the Sheriff in his official capacity alleging municipal liability under 42 U.S.C. § 1983 for failure to train correctional officers to handle mentally ill inmates.
At summary judgment the district court ruled for the Sheriff, finding no evidence of a policy or custom of inadequate training; Johnson appealed only the failure-to-train claim.
Evidence: officers testified to little or no recall of training; Sheriff produced evidence that all three completed a 40‑hour Crisis Intervention Training (CIT) course; records showed prior excessive-force complaints (101 complaints between 2009–2012, seven sustained) and PDF accreditation issues resolved before the incident.
The Eleventh Circuit held Johnson failed to show deliberate indifference or a pattern of similar constitutional violations putting the Sheriff on notice; affirmed summary judgment for the Sheriff.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Sheriff is liable under § 1983 for failure to train correctional officers to handle mentally ill inmates	Johnson: Sheriff failed to train; officers lacked memory of training; high number of force complaints and incidents in the mental‑health dorm show a pattern putting Sheriff on notice	Sheriff: Officers received 40‑hour CIT; prior complaints and accreditation issues do not show a pattern of similar constitutional violations or that training was inadequate	Affirmed: No genuine dispute that Sheriff was deliberately indifferent; plaintiff failed to show a pattern or constructive/actual notice requiring additional training

Connick v. Thompson, 563 U.S. 51 (failure‑to‑train claim requires deliberate indifference; usually a pattern of similar violations is needed)
City of Canton v. Harris, 489 U.S. 378 (liability for inadequate training requires proof that the municipality disregarded a known or obvious consequence)
Carter v. City of Melbourne, 731 F.3d 1161 (11th Cir.) (summary judgment review standard)
Weiland v. Palm Beach Cty. Sheriff’s Office, 792 F.3d 1313 (11th Cir.) (discussing pattern requirement for failure‑to‑train claims)
Mercado v. City of Orlando, 407 F.3d 1152 (11th Cir.) (plaintiff must point to other similar incidents to establish notice)
Lewis v. City of W. Palm Beach, 561 F.3d 1288 (11th Cir.) (focus on adequacy of training program generally, not single officer deficiencies)
Brooks v. Scheib, 813 F.2d 1191 (11th Cir.) (past complaints without merit do not show officials were aware of misconduct)