Brenda Toomer-Frazier v. City of Columbia
680 F. App'x 244
4th Cir.2017Background
- Plaintiff Brenda Toomer-Frazier sued the City of Columbia under 42 U.S.C. § 1981 alleging racial discrimination and retaliation in employment.
- The district court adopted the magistrate judge’s report and recommendation and granted summary judgment to the City.
- Toomer-Frazier appealed, arguing the City could be liable under the Supreme Court’s municipal-liability decision in City of Canton v. Harris for deliberate indifference or acquiescence even without an official discriminatory policy or custom.
- The Fourth Circuit reviewed whether Canton permits municipal liability absent an official policy or custom and whether Toomer-Frazier presented evidence of inadequate training tied to her injury.
- The court found Toomer-Frazier did not allege or produce evidence that City officials were inadequately trained, that any failure to train reflected deliberate indifference, or that any training deficiency caused her alleged disparate treatment.
- Because no municipal policy or custom or Canton-based failure-to-train theory was shown, the court affirmed the district court’s grant of summary judgment for the City.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the City can be liable under § 1981 without an official municipal policy or custom | Canton allows municipal liability based on deliberate indifference/knowledge and acquiescence even absent an official policy | City argued no policy/custom and no Canton-based failure-to-train claim supports liability | Held: Canton does not extend that far; no liability without policy/custom or proper Canton showing |
| Whether a failure-to-train claim under Canton was adequately pleaded and supported | Toomer-Frazier suggested deliberate indifference/knowledge could support liability | City contended there was no evidence of inadequate training, deliberate indifference, or causation tying training to her injury | Held: Plaintiff failed to allege or show inadequate training, deliberate indifference, or causation; Canton inapplicable |
| Whether § 1981 claims against municipalities are governed by § 1983 standards | Plaintiff proceeded under § 1981 to seek municipal relief | City relied on controlling precedent limiting remedies against municipalities | Held: Court applied § 1983 municipal-liability standards (Jett and circuit precedent) to the § 1981 claim |
| Whether summary judgment for the City was appropriate | Toomer-Frazier argued triable issues existed on discrimination/retaliation and municipal liability | City argued absence of municipal policy/custom and lack of Canton evidence warranted summary judgment | Held: Summary judgment affirmed — plaintiff did not meet municipal-liability or Canton standards |
Key Cases Cited
- City of Canton v. Harris, 489 U.S. 378 (1989) (municipal liability for failure to train applies only where inadequate training shows deliberate indifference and is closely related to the plaintiff’s injury)
- Jett v. Dallas Independent School District, 491 U.S. 701 (1989) (limits certain claims against state actors to § 1983 rather than § 1981)
- Dennis v. City of Fairfax, 55 F.3d 151 (4th Cir. 1995) (applies Jett to limit discrimination/retaliation claims against state actors to § 1983 standards)
- Crowley v. Prince George’s County, 890 F.2d 683 (4th Cir. 1989) (similar application of § 1983 standards to municipal liability issues)