No Monell

In Cambric v. City of Corpus Christi, the Fifth Circuit affirmed the dismissal of a § 1983 claim against a municipality for failure to adequately plead municipal liability under Monell. The plaintiff alleged that the city engaged in selective enforcement of its building code in violation of the Equal Protection Clause and sought to hold the city liable based on a “pattern, practice, and custom” of selective enforcement.

The Court held that the plaintiff’s allegations were insufficient to establish an actionable custom for municipal liability purposes. Although the plaintiff cited one instance of allegedly unequal treatment—the city’s support for a different historical restoration project—the court found this comparison inadequate to demonstrate a pattern of constitutional violations.

A concurrence clarified that the court’s recent decision in Hershey v. City of Bossier City, which allowed a single-incident Monell claim to survive dismissal on a failure-to-train theory, should not extend to claims alleging that policymakers selectively enforced a statute or ordinance. No. 25-40126, Mar. 13, 2026