Scarborough v. Frederick Cnty. Sch. Bd. 517 F. Supp. 3d 569 (W.D. Va. 2021) from Sovine and Angelo's Twitter accounts on the same day she was blocked. Therefore, as it pertains to Sovine and Angelo, the court also cannot afford relief regarding postdeprivation process on these facts. See Davison , 267 F. Supp. 3d at 722 ("The period during which Plaintiff was banned from Defendants' Facebook page was of such a limited duration that neither Defendant nor the County government had an opportunity to provide any postdeprivation process."). The court agrees with Defendants Sovine and Angelo that Count II is implausible on its face as to any postdeprivation review. The court will therefore dismiss Count II against Sovine and Angelo with prejudice. C. Count III: 42 U.S.C. § 1983 — Failure to Train In her final cause of action, Scarborough alleges that Defendant FCSB failed to train its officials on acceptable social-media practices, and that this failure contributed to those officials' infringement of her First Amendment rights. Defendants move to dismiss this failure-to-train claim, arguing that Scarborough failed to plead sufficient facts establishing a prima facie case for this cause of action under § 1983. "To impose liability on a supervisor for the failure to train subordinates, a plaintiff must plead and prove that: (1) the subordinates actually violated the plaintiff's constitutional or statutory rights; (2) the supervisor failed to train properly the subordinates thus illustrating a ‘deliberate indifference’ to the rights of the persons with whom the subordinates come into contact; and (3) this failure to train actually caused the subordinates to violate the plaintiff's rights." Brown v. Mitchell , 308 F. Supp. 2d 682, 701 (E.D. Va. 2004) (citing City of Canton v. Harris , 489 U.S. 378, 388–92, 109 S.Ct. 1197, 103 L.Ed.2d 412 (1989) ). To satisfy the first element, a plaintiff must allege that the defendant's subordinates actually violated her rights. Id. at 702 ; Young v. City of Mt. Ranier , 585 238 F.3d 567, 579 (4th Cir. 2001) ("The law is quite clear ... that a section 1983 failure-to-train claim cannot be maintained against a governmental employer in a case where there is no underlying constitutional violation by the employee."). Under the second element, "in order to have exhibited deliberate indifference, the supervisory power must have had notice of the constitutional or statutory violation, and thereafter must have consciously chosen a particular course of action in response." Brown , 308 F. Supp. 2d at 703 ; City of Canton , 489 U.S. at 389, 109 S.Ct. 1197 ("Only where a failure to train reflects a ‘deliberate’ or ‘conscious’ choice by a municipality—a ‘policy’ as defined by our prior cases—can a city be liable for such failure under § 1983."). "It is generally acknowledged that, if the supervisory power is actually aware of the fact that its subordinates are regularly violating constitutional or statutory *585 rights, and the supervisory power fails to implement a training program to quell this pattern, deliberate indifference exists." Id. (citations omitted). Finally, to survive a Rule 12(b)(6) motion, a plaintiff must allege a "causal nexus between the failure to train and the complained of injury." Id. at 706 (citing City of Canton , 489 U.S. at 391, 109 S.Ct. 1197 ). Scarborough has adequately pleaded a failure-totrain claim. As detailed above, she has alleged plausible violations of her First and Fourteenth Amendment rights against FCSB. To establish the second element—failure on the part of FCSB to train its officials on First Amendment considerations for social media—Scarborough points to Defendants' failure to take screenshots of her posts; their failure to post any terms and conditions on their social-media pages; their failure to warn her that her comments could be deleted; and their failure to give her notice and an opportunity to be heard prior to deleting her comments and banning her from the platforms. These acts and omissions, Scarborough argues, support the inference that these officials were 12