Danielle Washington v. Housing Authority of the City of Columbia, 58 F.4th 170

Calvin Witherspoon died of carbon monoxide poisoning in January 2019 at Allen Benedict Court, a complex owned and maintained by the City of Columbia Housing Authority (HA); the fatal leak traced to a faulty, 30‑year‑old gas furnace.
The HA had not performed regular inspections or preventative maintenance; no carbon monoxide detectors were present in any of the complex’s 244 units.
Post‑incident inspections revealed hundreds of code violations across the complex; the HA had only one inspector for roughly 2,600 units.
In 2017 the HA adopted a “Life‑Threatening Conditions” policy requiring prompt installation of CO detectors in privately owned properties but elected not to apply that policy to its own properties.
Plaintiff (Witherspoon’s daughter and estate representative) sued under 42 U.S.C. § 1983 alleging a Fourteenth Amendment substantive‑due‑process violation (bodily integrity) and a Monell claim that HA policies/customs and failure to train manifested deliberate indifference.
The district court dismissed for failure to state a claim; the Fourth Circuit reversed and remanded, finding the complaint plausibly alleged deliberate indifference and municipal causation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether HA’s conduct violated substantive due process (standard of culpability)	Washington: HA’s longstanding failure to maintain furnaces, lack of CO detectors, and deliberate choice not to apply its own life‑threatening‑conditions policy to HA properties shows deliberate indifference to residents’ safety.	HA: Allegations amount to negligence; plaintiff fails to plead subjective knowledge of a specific risk necessary for a due‑process violation.	The court: Deliberate indifference is the appropriate standard and the complaint plausibly alleges HA subjectively recognized the risk and acted inappropriately, satisfying conscience‑shocking requirement.
Whether plaintiff pleaded Monell causation (municipal liability)	Washington: HA’s specific policies/customs (excluding HA properties from Policy 8‑1.C, understaffing, nonuniform repair system, willful neglect to seek federal grants, and insufficient training) were the moving force behind Witherspoon’s death.	HA: Allegations are generalized, scattershot, and lack the specificity and causal nexus required under Monell and Bryan County.	The court: Plaintiff identified specific deficiencies and alleged facts showing a direct causal link plausibly tying those policies/customs to the constitutional injury; Monell causation adequately pleaded.

Monell v. Department of Social Services of City of New York, 436 U.S. 658 (municipal liability requires a policy or custom causing the constitutional deprivation)
County of Sacramento v. Lewis, 523 U.S. 833 (substantive due process requires conduct that shocks the conscience)
Dean ex rel. Harkness v. McKinney, 976 F.3d 407 (deliberate indifference standard and application where extended reflection was possible)
Owens v. Baltimore City State’s Att’ys Off., 767 F.3d 379 (pleading standard and showing municipal custom beyond labels and conclusions)
Ashcroft v. Iqbal, 556 U.S. 662 (plausibility pleading standard)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard)
Bd. of County Comm’rs of Bryan County v. Brown, 520 U.S. 397 (rigorous causation requirement for municipal liability)
Makdessi v. Fields, 789 F.3d 126 (willful blindness and inference of subjective knowledge)
Castro v. County of Los Angeles, 833 F.3d 1060 (adoption of safety regulations can demonstrate municipal knowledge of risk)