reversing dismissal of complaint asserting police liability for constitutional violation arising from police department's custom when department failed to take action to correct pattern of officer misconduct, and noting police department's notice and indifference could be inferred from sufficiently pervasive pattern of misconduct

In Owens, 767 F.3d at 402, the Fourth Circuit reiterated that to establish a Monell claim based on custom and practice, the plaintiff “must point to a ‘persistent and widespread practice[] of municipal officials,' the ‘duration and frequency' of which indicate that policymakers (1) had actual or constructive knowledge of the conduct, and (2) failed to correct it due to their ‘deliberate indifference.'” (quoting Spell, 824 F.2d at 1386-91) (alteration in Owens).

In Owens, 767 F.3d at 395, the Fourth Circuit reiterated: "Qualified immunity protects government officials from liability for ‘civil damages insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known.’ "

In Owens, 767 F.3d at 402, the Fourth Circuit reiterated that, to establish a Monell claim, the plaintiff "must point to a ‘persistent and widespread practice[ ] of municipal officials,’ the ‘duration and frequency’ of which indicate that policymakers (1) had actual or constructive knowledge of the conduct, and (2) failed to correct it due to their ‘deliberate indifference.’ "