failure-to-discipline theory, Plaintiffs failure-to-supervise theory requires her to establish that the City acted with deliberate indifference. See Amnesty Am. v. Town of W. Hartford, 361 F.3d 113, 127-28 (2d Cir.2004); Vann v. City of New York, 72 F.3d 1040, 1049 (2d Cir.1995). “To prove such deliberate indifference, the plaintiff must show that the need for more or better supervision to protect against constitutional violations was obvious.” Vann, 72 F.3d at 1049. “An obvious need may be demonstrated through proof of repeated complaints of civil rights violations; deliberate indifference may be inferred if the complaints are followed by no meaningful attempt on the part of the municipality to investigate or to forestall further incidents.” Id.; see also Amnesty Am., 361 F.3d at 128 (<HOLDING>). Plaintiff submitted the three Individual
holding that a supervisor with no personal involvement may be liable for the constitutional violation of a subordinate for culpable action or inaction in the training supervision or control of his subordinates acquiescence in the constitutional deprivation  or reckless or callous indifference to the rights of others holding that in a prisoners eighth amendment claim of deliberate indifference to a serious medical need expert testimony is necessary when the seriousness of injury or illness would not be apparent to a lay person holding that failuretosupervise liability requires that the city had notice of a potentially serious problem of unconstitutional conduct such that the need for corrective action or supervision was obvious and the policymakers failure to investigate or rectify the situation evidences deliberate indifference rather than mere negligence or bureaucratic inaction holding that allegations that training was inadequate  the inadequate training constituted deliberate indifference  and the risk of constitutional injury as a result of such deliberate indifference  is very obvious were a formulaic recitation of the elements of a cause of action and were mere conclusions that did not without additional facts state a claim for failuretotrain liability holding that deliberate indifference to a serious medical need establishes an eighth amendment violation