Moreover, it held that a municipality also may be held liable for constitutional deprivations caused by governmental custom. This holding imposes liability upon an employer for the wrongful actions of an employee, regardless of the absence of fault by the employer. In subsequent decisions, the Court has expressed divergent opinions on what constitutes 'custom' or inadequate supervision and training necessary to establish liability. Some justices would permit a finding of custom based on a single incident of unconstitutional conduct, others would require a showing of deliberate indifference to a past pattern of misconduct, while other would require a showing of gross negligence. Lower courts also have disagreed over the appropriate standard for a custom of inadequate police training or supervision. Regardless of what standard the courts adopt, there are steps that police departments can take to minimize liability. Training and supervisory procedures for high-risk activities should be scrutinized to determine that they are not per se unconstitutional. Special attention should be given to firearms, pursuits, use of deadly and nonlethal force, constitutional criminal law and civil rights, detention facility safety, handling of citizen complaints, and hiring. 17 footnotes.