History of Unrelated Complaints Insufficient to Support Section 1983 Liability
In 2019, Audrey Malone (“Malone”) filed a pro se 42 U.S.C. § 1983 action against the City of Atlanta, Georgia (“City”). In her action, she alleged that the City's failure to train its police officers resulted in a violation of her Fourth and Fourteenth Amendment rights, including an unconstitutional traffic stop, false arrest, false imprisonment, an unlawful seizure of her vehicle and personal items, and deliberate indifference to her serious medical needs. In support of her