In fact, Plaintiff does not even explain the very nature of the alleged policy. Plaintiff cannot make out a Monell claim through the “mere assertion that a [municipal] custom or policy exists[.]” Massari v. Ryerse, No. 23-CV-446 (MJR), 2024 WL 2116827, at *4 (W.D.N.Y. Mar. 28, 2024); see Green, 96 F.Supp.3d at 302-03 (finding that a complaint containing “quintessentially boilerplate language echoing the requirements contained in Monell” was insufficient to establish the existence of an actionable municipal policy); Riccio v. Town of Old Saybrook, No. 21-CV-821 (SVN), 2022 WL 4585650, at *3 (D. Conn. Sept. 29, 2022). Next, Plaintiff fails to show that the actions of a policymaking official created a policy that violated his constitutional rights.
To state a claim for failure to supervise, a plaintiff must allege sufficient facts to allow the court to infer that “(1) that defendants ‘should have known their inadequate supervision was so likely to result in the alleged deprivations so as constitute deliberate indifference'; that (2) there were ‘obvious and severe deficiencies in the ... defendants' supervision that reflect a purposeful rather than negligent course of action'; and (3) that there was ‘a causal relationship between the failure to supervise and the alleged deprivations to plaintiffs.'” Riccio v. Town of Old Saybrook, No. 3:21-CV-821 (SVN), 2022 WL 4585650, at *3 (D. Conn. Sept. 29, 2022) (citing Reynolds, 506 F.3d at 193).
A municipality may also be liable for its failure to train or supervise employees if the failure “display[s] a deliberate indifference to the constitutional rights of those within its jurisdiction.'” Connick, 563 U.S. at 61 (quoting Kern v. City of Rochester, 93 F.3d 38, 44 (2d Cir. 1996)); Riccio v. Town of Old Saybrook, No. 3:21-CV-821 (SVN), 2022 WL 4585650, at *2 (D. Conn. Sept. 29, 2022) (identifying one type of Monell liability as “a failure to properly train or supervise municipal employees that amounts to deliberate indifference to the rights of those with whom municipal employees will come into contact”).
. Second, even generously construing the SAC, Grazette has failed to allege a policy or custom that subjected him to the deprivation of a constitutional right, and, therefore, his “conclusory allegations fail to allege a Monell claim.” Riccio v. Town of Old Saybrook, No. 21 Civ. 821 (SVN), 2022 WL 4585650, at *3 (D. Conn. Sept. 29, 2022); see Kraft v. City of New York, 696 F.Supp.2d 403, 420 (S.D.N.Y. 2010) (Although the “Second Circuit has recognized that involuntary commitment to a mental hospital cannot be executed by the State without due process of law[,]” it has also observed “the process for involuntary commitment under [New York's] M[ental] H[ygiene] L[aw] meets the requirements of procedural due process”), aff'd, 441 Fed.Appx. 24 (2d Cir. 2011)