Price v. City of N.Y. 15 Civ. 5871 (KPF) (S.D.N.Y. Jun. 25, 2018) the Court will not afford Plaintiff's memorandum of law the special solicitude normally afforded to pro se submissions. See Spira v. J.P. Morgan Chase & Co., 466 F. App'x 20, 22 n.1 (2d Cir. 2012) (summary order); Ibrahim v. United States, 868 F. Supp. 2d 27, 29 (E.D.N.Y. 2012); see generally In re Fengling Liu, 664 F.3d 367, 369-71 (2d Cir. 2011) (holding that an attorney's undisclosed ghostwriting may violate the attorney's duty of candor). But because there is no clear indication that the FAC was prepared by an attorney, the Court will continue to afford Plaintiff special solicitude pleading's in allegations. interpreting See Tracy the v. Freshwater, 623 F.3d 90, 101 (2d Cir. 2010). 14 The motion should be denied "unless it appears beyond doubt that the plaintiff can prove no set of facts in support of [her] claim which would entitle [her] to relief." Matson v. Bd. of Educ. of City Sch. Dist. of N.Y., 631 F.3d 57, 63 (2d Cir. 2011) (citation omitted, alterations in original). In applying these standards, the Second Circuit has specifically cautioned against hastily dismissing complaints alleging civil rights violations. See McGarry v. Pallito, 687 F.3d 505, 510 (2d Cir. 2012); see also Tarshis v. Riese Org., 211 F.3d 30, 35 (2d Cir. 2000) (collecting cases). *14 2. Civil Rights Claims Under 42 U.S.C. § 1983 The Ku Klux Klan Act of 1871, amended and codified in relevant part as 42 U.S.C. § 1983, created a private right of action against any person acting under color of law who subjects another to the "deprivation of any rights, privileges, or immunities secured by the Constitution and laws." Accordingly, to sustain an action under § 1983, the conduct at issue "must have been committed by a person acting under color of state law" and "must have deprived a person of rights, privileges, or immunities secured by the Constitution or laws of the United States." Pitchell v. Callan, 13 F.3d 545, 547 (2d Cir. 1994); see also West v. Atkins, 487 U.S. 42, 48-49 (1988). 15 When a plaintiff sues a municipality under § 1983, it is not enough for the plaintiff to allege that one of the municipality's employees or agents engaged in some wrongdoing. The plaintiff must show that the municipality itself caused the violation of the plaintiff's rights. See Connick v. Thompson, 563 U.S. 51, 60 (2011) ("A municipality or other local government may be liable under this section [1983] if the governmental body itself 'subjects' a person to a deprivation of rights or 'causes' a person 'to be subjected' to such deprivation.") (quoting Monell v. Dep't of Soc. Servs. of City of N.Y., 436 U.S. 658, 692 (1978)); accord Cash v. Cty. of Erie, 654 F.3d 324, 333 (2d Cir. 2011). In other words, to state a § 1983 claim against a municipality, the plaintiff must allege facts showing (i) the existence of a municipal policy, custom, or practice, and (ii) that the policy, custom, or practice caused the violation of the plaintiff's *15 constitutional rights. See Bd. of Cty. Comm'rs of Bryan Cty. v. Brown, 520 U.S. 397, 403 (1997); Jones v. Town of E. Haven, 691 F.3d 72, 80 (2d Cir. 2012). There are several ways that a plaintiff can state a claim of municipality liability under § 1983. A plaintiff can, for instance, plead (i) a formal policy officially promulgated by the municipality caused the constitutional violation, see Monell, 436 U.S. at 690; (ii) the official responsible for establishing the policy, with respect to the subject matter in question to the specific action, caused the constitutional violation, see Pembauer v. City of Cincinnati, 475 U.S. 469, 483-84 (1986) (plurality opinion); (iii) the existence of an unlawful practice by subordinate officials, which was so widespread and well settled as to constitute a "custom or usage" of the municipality, caused the constitutional violation, see City of St. Louis v. Praprotnik, 485 U.S. 112, 127-30 (1985) (plurality opinion); Sorlucco v. N.Y.C. Police Dep't, 971 F.2d 864, 871 (2d Cir. 1992); or (iv) a failure to train or supervise that amounts to "deliberate indifference" to the rights of those with whom the 7