Case Citator › Beresford N. Springer v. Gretchen Seaman

Beresford N. Springer v. Gretchen Seaman

Is it still good law? What later courts have actually done to this case.

Abrogated
Court
First Circuit
Citation
821 F.2d 871
Decided
Confirmed treatments
2
Flagged citations read
29 of 29
Citing cases (total)
29
Treatment dates
1988–1989
Abrogated
A reviewed court treats this case as abrogated by later authority. Beresford N. Springer v. Gretchen Seaman was abrogated in part by the Supreme Court's decision in Jett v. Dallas Independent School District. Its rule permitting municipal liability under 42 U.S.C. § 1981 based on employees' acts through respondeat superior no longer controls; Jett requires a municipal policy or custom and a claim under § 1983.
More on how this was screened

Springer's proximate cause analysis was unaffected. The Fifth Circuit had also expressly rejected its municipal liability rule. Both treatments are listed below. All 29 flagged citations have been read.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

29 later cases cite Beresford N. Springer v. Gretchen Seaman; 29 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

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Treatments

Abrogated

  • The Supreme Court displaced Springer's rule allowing municipal respondeat superior liability for a violation of § 1981, requiring a § 1983 claim based on municipal policy or custom.

    Jett v. Dallas Independent School District · Supreme Court of the United States · filed

    Because the Court of Appeals’ conclusion that local governmental bodies cannot be held liable under a theory of respondeat superior for their employees’ violations of the rights guaranteed by § 1981 conflicts with the decisions of other Courts of Appeals, see, e. g., Springer v. Seamen, 821 F. 2d 871, 880-881 (CA1 1987); Leonard v. Frankfort Electric and Water Plant Bd., 752 F. 2d 189, 194, n. 9 (CA6 1985) (dictum), we granted Norman Jett’s petition for certiorari in No. 87-2084. ... We hold that the express “action at law” provided by § 1983 for the “deprivation of any rights, privileges, or immunities secured by the Constitution and laws,” provides the exclusive federal damages remedy for the violation of the rights guaranteed by § 1981 when the claim is pressed against a state actor. Thus to prevail on his claim for damages against the school district, petitioner must show that the violation of his “right to make contracts” protected by § 1981 was caused by a custom or policy within the meaning of Monell and subsequent cases.
    Read the full opinion on CourtListener →

Declined to follow

  • The Fifth Circuit rejected Springer's contrary rule on municipal respondeat superior liability under § 1981.

    Norman Jett v. Dallas Independent School District · Fifth Circuit · filed

    We are aware that Springer v. Seamen, 821 F.2d 871, 880-81 (1st Cir.1987), declined to follow our opinion in this respect. Springer, however, does not persuade us to a contrary result.
    Read the full opinion on CourtListener →

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