that Bogren failed to show that similarly situated white and male probationary troopers were treated more favorably, and her equal protection claim fails for that reason. For the same reasons discussed in relation to Bogren’s Title VII discriminatory discharge claim, see supra § H.A., we too agree that Bogren fails to present sufficient evidence that she was treated less favorably than other similarly situated troopers. B. § 1981 Bogren also seeks to recover against the individual defendants pursuant to 42 U.S.C. § 1981 (1994). Section 1981, as amended by the Civil Rights Act of 1991, provides a cause of action for discrimination in the employment relationship. See 42 U.S.C.1981(a), (b); see also Richmond v. Board of Regents of the Univ. of Minn., 957 F.2d 595, 597 (8th Cir.1992) (<HOLDING>). As an initial matter, Fraser and Hodapp argue
recognizing that prior supreme court precedent to the contrary see patterson v mclean credit union 491 us 164 109 sct 2363 105 led2d 132 1989 was superceded by the 1991 amendments holding uncharged acts of violence evidence of  the background of the charges the parties familiarity with one another and their concert of action  quoting united states v oleary 739 f2d 135 136 3d cir1984 cert denied 469 us 1107 105 sct 782 83 led2d 776 1985 cert denied 493 us 821 110 sct 78 107 led2d 44 1989 holding that ohio revcode  230509d is the most logical and appropriate statute of limitations in a  1983 action based on the united states supreme court holding in owens v okure 488 us 235 109 sct 573 102 led2d 594 1989  holding that the rule announced in miller v alabama 567 us  132 sct 2455 183 led2d 407 2012 applies retroactively on collateral review recognizing that the circuits vary in their interpretations of  1915 but noting that neitzke v williams  us  109 sct 1827 104 led2d 338 1989 declined to rule on the preferred approach