Different courts attribute various meanings to the term "official policy," but any definition includes the concept of a policy officially promulgated by decision-makers and concept of custom. State law determines who is an official policymaker whose actions might lead to municipal liability. An agency is not liable for the actions of lower-level administrative officials. If a failure to train police officers amounts to deliberate indifference, cities or municipalities can be sued. The "official policy" standard for liability eliminates prior decisions that based liability on the degree of negligence rather than on agency complicity and requires written departmental policies and a careful review of the policies to ensure that they are in accord with statutes and the Constitution. 1 note