In Bryan County v. Brown, 520 U.S. 397 (1997), the alleged municipal action was a sheriffs decision to hire a relative, Stacy Burns, without subjecting him to an adequate background check. Bryan County, 520 U.S. at 401. Burns, who had been convicted of misdemeanors including assault and battery, later allegedly used excessive force against the plaintiff, Jill Brown. See id. at 400-01. There was no allegation that Bryan County had a policy of failing to screen applicants or one of using excessive force. Rather, Brown sought to hold the county liable based on the sheriffs single act of failing to properly screen Burnss background. The Bryan County Court carefully distinguished between the situation presented to it and a situation in which a municipality is alleged to have formulated a policy. In the first instance involving a single action by a policymaker, the Court held that rigorous standards of culpability and causation must be applied to ensure that the municipality is not held liable solely for the actions of its employee. 520 U.S. at 405. However, the Court also carefully noted that where a plaintiff claims that a particular municipal action itself violates federal law, or directs an employee to do so, the allegation renders issues of fault and causation straightforward. Id. at 404.