- posted: Feb. 21, 2024
Leak v. City of Paterson, No. 22-cv-06994 (MEF)(JBC), 2025 U.S. Dist. LEXIS 30215, at *11 n.10 (D.N.J. Feb. 19, 2025)
but see Khalil v. City of Paterson, 2018 WL 6168191, *5 (D.N.J. Nov. 26, 2018) (allegations about a statistical increase in excessive force complaints were not enough, standing alone, to support a Monell failure-to-train claim); Alsaidi v. City of Paterson, 2024 WL 4053085, at *7-*8 (D.N.J. Sept. 5, 2024) (references to arrests of police officers, without citations, and a citation to a different case that discussed statistics about excessive force complaints in the same defendant-city, were insufficient to plausibly state a claim). Why does it matter that conduct repeats itself? Because a custom is based on practices so "persistent" and "longstanding," Lindke v. Freed, 601 U.S. 187, 200 (2024); Jett, 491 U.S. at 737, that they harden into "standard operating procedure". Jett, 491 U.S. at 737.
