Jett v. Dallas Independent School District

What This Case Is About

Norman Jett, a white teacher, athletic director, and head football coach at a predominantly Black high school in Dallas, claimed he was reassigned because of his race. He sued the Dallas Independent School District under both 42 U.S.C. § 1983 and § 1981, arguing the district was vicariously liable for the racially motivated actions of its employees. The Supreme Court held that § 1983 is the exclusive remedy for § 1981 claims against state actors, and that respondeat superior liability is unavailable.

The Facts

Jett repeatedly clashed with his principal, Todd, over school policies and the football program. Todd recommended that Jett be relieved of his coaching and athletic director duties. Superintendent Wright affirmed the recommendation and reassigned Jett to a teaching position at another school with no coaching duties. Jett alleged that Todd’s recommendation was racially motivated and that the school district discriminated against him on the basis of race in violation of § 1981, § 1983, and the Equal Protection Clause. A jury found in Jett’s favor on all counts. The Fifth Circuit reversed in part, finding that the jury instructions on municipal liability were deficient under Monell.

What the Court Decided

The Supreme Court held that § 1983 provides the exclusive federal damages remedy for § 1981 violations by state actors. This meant Jett could not use § 1981 as a standalone vehicle to impose broader liability — specifically respondeat superior — on the school district. Because Monell held that municipalities cannot be held vicariously liable under § 1983, the same limitation applies when the underlying right comes from § 1981.

The Court reasoned that allowing respondeat superior liability under § 1981 but not under § 1983 would let plaintiffs circumvent § 1983’s “carefully crafted remedial scheme” through artful pleading. The Court also addressed the final policymaker doctrine, noting that municipal liability under § 1983 requires showing that the decision was made by an official with final policymaking authority or reflected a well-settled custom.

Why This Case Matters for Your § 1983 Case

Jett is essential for understanding the relationship between § 1981 and § 1983:

• No respondeat superior: A municipality cannot be held vicariously liable for an employee’s racial discrimination under either § 1981 or § 1983. You must show a policy or custom or that the employee was a final policymaker.
• § 1983 as exclusive remedy: When suing state actors for violations of federal statutory rights (including § 1981), § 1983 is the exclusive vehicle. This means all of § 1983’s requirements — including the Monell framework — apply.
• Final policymaker analysis: To hold a school district or municipality liable, you must identify who had final policymaking authority over the relevant decision. A mid-level supervisor’s decision is not enough unless that supervisor had final authority delegated by the governing body.

Key Takeaway

When suing a municipality or school district for racial discrimination, § 1983 is the exclusive federal damages remedy — and the Monell framework applies, meaning you must prove a policy, custom, or final policymaker decision rather than relying on respondeat superior.