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
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.
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.