Doe v. Wayne County School District, 2:24-cv-00005

Background

Plaintiff, Jane Doe, was a minor student at Wayne County High School during the 2021-2022 academic year.
In October 2021, JROTC instructor Harold Hill allegedly assaulted Doe during class; Doe immediately sought help from school administration and law enforcement.
Subsequent to the incident, Doe experienced alleged retaliation and harassment from both students and school staff, including bullying, a lack of promised protective measures, and derogatory comments from a new JROTC instructor.
Doe's parents repeatedly sought intervention and protections from the school administration, which allegedly failed to implement agreed-upon safety measures and did not address ongoing harassment.
As a result, Doe's grades dropped, she withdrew from school activities and suffered emotional distress; she and her family allege the school's actions and inactions deprived her of educational opportunities.
Doe sued the Wayne County School District and Harold Hill, asserting claims under Title IX (sexual harassment and retaliation), 42 U.S.C. § 1983 (failure to train/custom/policy), and related torts. The School District moved to dismiss all claims against it.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Title IX: Teacher-on-Student Harassment	School officials had actual knowledge of the assault and failed to take effective remedial action afterward, constituting deliberate indifference.	District lacked actual notice of Hill's prior misconduct before the assault; after Hill left, no further teacher harassment possible.	Plaintiff plausibly alleged post-assault deliberate indifference; motion to dismiss denied.
Title IX: Student-on-Student Harassment	School officials were on notice of peer harassment; inaction and lack of protective measures amounted to deliberate indifference that barred Doe’s access to education.	Peer taunting was not sufficiently severe, pervasive, or objectively offensive; school not deliberately indifferent.	Doe plausibly alleged severe, pervasive harassment and deliberate indifference; motion to dismiss denied.
Title IX: Retaliation	Reporting the assault led to adverse actions (search, teacher comments, lack of protection) causally linked to the report.	School inaction and alleged adverse events not sufficiently linked to the protected activity.	Plaintiff plausibly pled reporting, adverse actions, and causation. Motion to dismiss denied.
§ 1983: Failure to Train/Custom/Policy	District had an obvious and deliberate failure to train or policy/custom causing Doe’s deprivation of rights.	Only a single incident; no pattern or obvious need shown; failure to train theory not supported.	Allegations sufficient at pleading stage to plausibly allege a policy/custom and causation; motion denied.

Key Cases Cited

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets out plausibility pleading standard under Rule 8)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (articulates plausibility standard for motions to dismiss)
Davis v. Monroe Cnty. Bd. of Educ., 526 U.S. 629 (1999) (defines Title IX standards for harassment and school liability)
Gebser v. Lago Vista Indep. Sch. Dist., 524 U.S. 274 (1998) (actual notice and deliberate indifference standard for Title IX)
Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978) (municipal liability under § 1983 requires official policy or custom)
City of Canton v. Harris, 489 U.S. 378 (1989) (failure to train as basis for municipal § 1983 liability)
Ray v. Spirit Airlines, Inc., 836 F.3d 1340 (11th Cir. 2016) (motion to dismiss standard on factual allegations)
Doe v. Sch. Bd. of Broward Cnty., Fla., 604 F.3d 1248 (11th Cir. 2010) (Title IX: actual notice, appropriate person, deliberate indifference)
Hill v. Cundiff, 797 F.3d 948 (11th Cir. 2015) (standards for Title IX student-on-student claims)