Starr v. City of Palestine, Texas, 6:24-cv-00426

Tracy Lynn Starr sued the City of Palestine, Texas, alleging violations of the Equal Protection Clause of the Fourteenth Amendment under 42 U.S.C. § 1983.
Starr argued she was denied the ability to register her address by a police officer, and claimed this constituted a “class-of-one” equal protection violation.
The City moved to dismiss the case for failure to state a claim.
The magistrate judge recommended dismissal with prejudice, primarily based on Starr’s failure to plead the necessary Monell elements.
Starr objected, submitting ChatGPT-generated responses, but the objections focused on the merits rather than the deficiencies identified in the report.
The district court reviewed the matter de novo and adopted the magistrate’s recommendation, dismissing the case with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there a viable class-of-one equal protection claim?	Starr properly pleaded a class-of-one equal protection violation.	Starr failed to plead the required Monell elements: no official policy, custom, or policymaker implicated.	Plaintiff failed to state a claim; dismissal granted.
Did Starr sufficiently allege municipal policy or custom?	Claimed denial of registration resulted from City actions.	No allegation of an official or widespread practice; only a single police officer’s action cited.	No official policy or custom pleaded; claim dismissed.
Did Starr sufficiently identify a policymaker?	Police officer responsible for refusal is policymaker.	Police officers are not policymakers; policymaking authority not shown.	No policymaker identified; claim dismissed.
Were objections to the report valid?	Objections challenged dismissal on class-of-one grounds.	Objections did not address Monell pleading deficiencies.	Objections overruled.

Monell v. Department of Social Services, 436 U.S. 658 (1978) (municipal liability under § 1983 requires pleading an official policy/custom and policymaker involvement)
Douglass v. United Servs. Auto. Ass'n, 79 F.3d 1415 (5th Cir. 1996) (standard for de novo review of magistrate judge’s report)
Pena v. City of Rio Grande City, 879 F.3d 613 (5th Cir. 2018) (custom knowledge must be attributable to a policymaker for municipal liability)
Peterson v. City of Fort Worth, 588 F.3d 838 (5th Cir. 2009) (distinction between policymaking and decision-making authority in § 1983 cases)