Jett v. Dallas Independent School District

Norman Jett (plaintiff), a successful White football coach and teacher at Dallas Independent School District (DISD) (defendant), did not get along with DISD’s African American principal, Dr. Fredrick Todd. After Jett lost a football game, Jett told the game officials in the locker room that Jett would never again hire African Americans to officiate a game. In response, Todd contacted DISD’s director of athletics and recommended Jett’s removal as coach. Jett met with Linus Wright, DISD’s superintendent, and told Wright that Todd’s criticisms of Jett were motivated by racial animus and that Todd really just wanted to replace Jett with an African American coach. Wright reassigned Jett to a teaching job with no coaching duties. Jett sued DISD and Todd under 42 U.S.C. §§ 1981 and 1983 alleging that Jett’s removal was racially motivated and violated the equal-protection clause. The jury awarded Jett damages against DISD for Todd’s improper actions. DISD filed a motion for judgment notwithstanding the verdict, arguing the damages against DISD were improper because Jett was not removed due to a policy or custom of the school district. The district court found that the claim was cognizable under §§ 1981 and 1983 and that damages under § 1981 could be imposed on DISD for Todd’s actions through respondeat superior. The court of appeals reversed, and Jett appealed.