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cases/42usc1981/f3d-927-961-freeman-v-metro-water-reclamation-dist.case

Source: cases/42usc1981/f3d-927-961-freeman-v-metro-water-reclamation-dist.case

Case source: https://www.neochart.com/catalog/cases/f3d/volume_927/0961_01/index.html

Verbatim annotated passages

that law does not create a private right of action against public bodies unless the plaintiff has raised Monell allegations.
We affirm with respect to Freeman's contention that the District fired him pursuant to a policy that is unlawful under Monell v. Department of Social Services. , 436 U.S. 658, 694-95, 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978).
Because the district court recruited four attorneys to assist Freeman with pleading this claim adequately, and he had four opportunities to amend his complaint to do so and yet never did, we see no abuse of discretion in the dismissal of this claim without additional leave to amend.

Exact source text

casedsl 1.2
# author: Flash2 (gemini-3.8-flash-high)
# triaged-by: Fable (2026-11-10)

case /f3d/927/0961-01
  name    Freeman v. Metro. Water Reclamation Dist. of Greater Chi.
  cite    927 F.3d 961 (2019)
  court   United States Court of Appeals for the Seventh Circuit
  date    2019-06-14
  url     catalog/cases/f3d/volume_927/0961_01/index.html
  source  ir/caselaw/f3d_927.jsonl sha1=14f6547af084b3b6ac9689f4245a93cc86ff7ffa chars=11286

opinion maj : per-curiam @0..11286 controlling
? holding: the race-discrimination pleading ruling (a bare allegation of discharge because of race suffices) is stated for the Section 1983 and Title VII claims only; the opinion says the Section 1981 claim against this public body needs Monell allegations, which it holds inadequate. The Section 1981 result is therefore recorded as claimant-lost and no racial-intent block is kept, although the mandate remands "race ... discrimination claims" generally.

law 42usc1981
  role    applied
  posture civil; Sections 1981 and 1983 race-discrimination discharge claims against a municipal corporation; Rule 12(b)(6) dismissal vacated as to Section 1983/Title VII/ADA discrimination claims, affirmed as to the Monell policy claim on which the Section 1981 claim depends (CA7)
  result  claimant-lost

element protected-person : satisfied [pleaded]
  route   race
  pattern african-american
  fact @3769..3875 [supports] | He alleges that the District fired him "due to his race" (African-American) and "disability" (alcoholism).

element own-contract : satisfied [pleaded]
  route   employment-relationship
  pattern probationary-at-will-plant-operator
  fact @915..1002 [supports] | Freeman began working for the District in May 2015 as an operator of a treatment plant.
  fact @1326..1418 [supports] | In his first year, Freeman, like all new hires, was a probationary worker, employed at will.

element contractual-impairment : satisfied [pleaded]
  route   employment-contract
  pattern discharge-of-probationary-worker
  fact @2423..2516 [supports] | The District fired Freeman while he was on probation, asserting "unsatisfactory performance."

element state-remedial-route : not-satisfied [pleaded]
  route   policy-or-custom
  pattern alleged-disproportionate-firing-of-black-probationers-without-saying-disparate-treatment-or-impact
  fact @9698..9805 [supports] | Freeman alleges that the District disproportionately fires probationary employees who are African-American.
  fact @9806..9967 [cuts-against absent] | But Freeman does not allege whether the policy is to treat African-Americans disparately or that the District's probation powers have a disparate impact on them.
  fact @1003..1043 [neutral] | The District is a municipal corporation.
  rule @9479..9603 | that law does not create a private right of action against public bodies unless the plaintiff has raised Monell allegations.
  held @496..717 | We affirm with respect to Freeman's contention that the District fired him pursuant to a policy that is unlawful under Monell v. Department of Social Services. , 436 U.S. 658, 694-95, 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978).
  held @10206..10489 | Because the district court recruited four attorneys to assist Freeman with pleading this claim adequately, and he had four opportunities to amend his complaint to do so and yet never did, we see no abuse of discretion in the dismissal of this claim without additional leave to amend.