## Facts

- Norman Jett, a white teacher and head football coach at a predominantly Black Dallas high school, had repeated conflicts with the school principal, Frederick Todd, over school policies and management of the football program.
- Todd recommended that Jett be removed as athletic director and coach.
- Superintendent W. T. Wright approved the recommendation and reassigned Jett to a teaching position at another school without coaching duties.
- Jett alleged the recommendation and reassignment were racially motivated and sued the Dallas Independent School District (DISD) and officials under 42 U.S.C. §§ 1981 and 1983 and the Equal Protection Clause.
- A jury found for Jett, and the district court upheld the verdict.
- The court of appeals reversed in part and remanded, holding the municipal-liability instructions were deficient under Monell and rejecting municipal respondeat superior liability under § 1981.

## Issues

1. Whether a local governmental entity may be held liable under 42 U.S.C. § 1981 for employees’ conduct on a respondeat superior theory.
2. Whether § 1983 provides the exclusive federal damages remedy against state actors for violations of rights protected by § 1981.
3. What constitutes an “official policy or custom,” and who qualifies as a final policymaker, for municipal liability under § 1983.

## Decision

- The Supreme Court affirmed in part and remanded.
- A municipality may not be held liable for employees’ § 1981 violations on a respondeat superior theory.
- § 1983 is the exclusive federal damages remedy against state actors for violations of § 1981-protected rights.
- Municipal liability requires proof that the challenged action was taken pursuant to an official policy or custom, including action by an official with final policymaking authority in the relevant area.
- Remand was required because the jury instructions did not properly require findings tying the alleged discrimination to DISD policy/custom or to action by a final policymaker (or deliberate indifference by such a policymaker).

## Legal Principles

- Claims seeking damages from state actors for violations of § 1981 rights must proceed through § 1983.
- Municipalities are not vicariously liable for employees’ federal civil-rights violations; liability attaches only to the municipality’s own policy or custom.
- “Official policy or custom” includes formally adopted policies and well-settled practices that function as policy, and may include decisions by officials with final policymaking authority for the subject matter.
- Whether an official is a final policymaker is a legal determination grounded in state and local law allocating final authority.

## Conclusion

The Court held that plaintiffs suing municipal entities for race discrimination in contracting or employment must use § 1983, and they must satisfy Monell by proving the injury was caused by an official municipal policy, custom, or decision of a final policymaker, not merely by an employee’s discriminatory act.


Jett v. Dallas Indep. Sch. Dist., 491 U.S. 701 (1989)