In Altieri v. New York City Dep't of Educ., 2005 U.S. Dist. LEXIS 33342 (S.D.N.Y. Dec. 15, 2005), the federal court dismissed a Section 1983 action on summary judgment because "Plaintiffs have proffered no evidence from which a reasonable jury could conclude that [the defendant school superintendent's] allegedly retailatory actions were taken pursuant to any policy or widespread custom or usage of the" New York City Department of Education.
The plaintiffs, parent teacher association (PTA) officials, alleged they were terminated by a retaliatory action of the since-deceased city school district superintendent.