Summary
The Sixth Circuit affirmed dismissal of a civil rights action brought by an African-American contractor and his company against the City of Detroit and related entities, holding that the complaint failed to state plausible claims under 42 U.S.C. §§ 1981 and 1983 for race discrimination, retaliation, or due process violations. The plaintiffs alleged they were suspended from a federally funded demolition program and denied payment based on race and in retaliation for refusing to alter bid numbers and cooperating with an FBI investigation, but the court found the complaint lacked sufficient factual allegations—including any showing that similarly situated white contractors were treated differently or that a municipal policy or custom caused the alleged injuries under *Monell*. Individual defendants sued only in their official capacities were properly dismissed as duplicative of claims against the entities, and the district court did not abuse its discretion in declining supplemental jurisdiction over the state-law claims.
Topics
Practice areas
Questions Presented
- Whether the individual defendants were properly dismissed because they were sued only in their official capacities.
- Whether plaintiffs stated a claim for municipal liability under Monell for their § 1983 due process and retaliation claims.
- Whether plaintiffs stated a claim under 42 U.S.C. § 1981.
- Whether the district court properly declined to exercise supplemental jurisdiction over the state law claims.
- Whether the district court properly denied plaintiffs' motion for reconsideration.
Holdings
- The individual defendants were properly dismissed because they were sued only in their official capacities, and official-capacity claims are redundant with claims against the entity.
- Plaintiffs failed to state a Monell claim because they did not allege a policy or custom of the municipality that caused their injuries.
- Plaintiffs' § 1981 claim fails because § 1983 provides the exclusive remedy for § 1981 claims against state actors, and plaintiffs failed to state a Monell claim.
Key quotations
“This court reviews de novo a district court’s grant of a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6).” (10)
“It will survive a motion to dismiss if the plaintiff alleges facts that 'state a claim to relief that is plausible on its face' and that, if accepted as true, are sufficient to 'raise a right to relief above the speculative level.'” (10-11)
“A local government entity violates § 1983 when an official policy or custom deprives an individual of her constitutional rights.” (12)
Factual background
Plaintiffs, an African-American individual and his company, participated in a demolition program funded by federal Hardest Hit Funds administered by the Detroit Land Bank Authority. After an investigation by the Detroit Inspector General found that plaintiffs had submitted falsified photographs of sidewalk repairs, they were suspended from the program and not paid for certain work. Plaintiffs alleged race discrimination and retaliation, claiming they were treated differently than white contractors and were suspended for refusing to alter bid numbers and for cooperating with an FBI investigation. The complaint lacked specific factual allegations supporting these claims, including dates, identities, and comparator evidence.
Procedural history
The district court granted defendants' motions to dismiss the federal claims under Rule 12(b)(6) and declined to exercise supplemental jurisdiction over the state law claims, dismissing them without prejudice. Plaintiffs' motion for reconsideration was denied. Plaintiffs appealed.