129 F.4th 38
1st Cir.2025Background
- Plaintiff Adrianna Wadsworth, a Medomak Valley High School student (age 16–17), alleged prolonged, near-daily sexualized texting and in-person attention by Principal Andrew Cavanaugh (gifts, car, meetings, requests about birth control, sexually explicit remarks and epithets); relationship never became physical.
- School social worker Chuck Nguyen and assistant principals knew aspects of the relationship (frequent pull‑outs from class, nicknames, work for Cavanaugh); assistant principals did not inform superintendent; police later obtained Wadsworth’s texts and superintendent placed Cavanaugh on leave; Cavanaugh resigned; no criminal charges.
- Wadsworth sued under 42 U.S.C. § 1983 (substantive due process — bodily integrity; equal protection — hostile educational environment; supervisor liability; municipal liability for MSAD) and brought a Title IX claim against MSAD for deliberate indifference.
- District court dismissed some claims and granted summary judgment for defendants: it rejected a § 1983 supervisory claim against Nguyen, granted summary judgment to Cavanaugh on due process and on equal protection (qualified immunity), granted Nguyen summary judgment on state‑created‑danger, and granted MSAD summary judgment on § 1983 and Title IX.
- On appeal the First Circuit: affirmed dismissal of the substantive‑due‑process (bodily‑integrity) claim against Cavanaugh; reversed as to the equal‑protection hostile‑environment claim against Cavanaugh (finding triable issues and that qualified immunity did not bar the claim); affirmed dismissal/summary judgment as to Nguyen; affirmed municipal § 1983 claims dismissal but reversed the Title IX summary judgment as to MSAD (assistant principals may have had actual notice).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether non‑physical sexualized conduct by a principal can violate substantive due process (bodily integrity) | Wadsworth: pervasive sexualized harassment and abuse of authority invaded bodily‑integrity rights even without physical contact | Cavanaugh: bodily‑integrity claims require physical invasion; conduct was non‑physical so no due‑process violation; alternatively qualified immunity | Court: affirmed dismissal — plaintiff failed to show deprivation of the bodily‑integrity right as established in precedent (no physical intrusion alleged) |
| Whether Cavanaugh’s conduct violated Equal Protection (hostile educational environment) and whether qualified immunity applies | Wadsworth: texts, sexualized comments, nicknames, threats, meetings and abuse of power created objectively and subjectively hostile educational environment based on sex | Cavanaugh: either no equal‑protection violation or, if there was, the right was not clearly established so qualified immunity applies | Court: reversed summary judgment for Cavanaugh — a reasonable jury could find sexual harassment creating a hostile educational environment; qualified immunity not available on this record |
| Whether Nguyen is liable (supervisory / state‑created‑danger / equal protection) | Wadsworth: Nguyen knew of inappropriate conduct, normalized it, failed to report/stop it, and had authority to act | Nguyen: no control over Cavanaugh (so no supervisor liability); lacked knowledge of sexualized texts/content (so no state‑created‑danger); qualified immunity | Court: affirmed dismissal/summary judgment — no supervisory control established; equal‑protection allegations inadequate; state‑created‑danger claim fails (plaintiff waived challenge to conscience‑shocking/knowledge point) |
| Whether MSAD is liable (Monell failure‑to‑train/policy) and whether MSAD is liable under Title IX (deliberate indifference/notice) | Wadsworth: MSAD policies/training left a reporting gap and were deliberately indifferent, and assistant principals had notice such that Title IX deliberate indifference claim survives | MSAD: policy allowed reporting to APs or superintendent; training existed; no causal municipal policy failure; assistant principals lacked actual notice sufficient for Title IX | Court: affirmed summary judgment on Monell § 1983 theories (no deliberate indifference/policy gap shown); reversed as to Title IX — a reasonable jury could find assistant principals had notice and authority to take corrective action, so Title IX deliberate‑indifference claim remanded |
Key Cases Cited
- Vacco v. Quill, 521 U.S. 793 (1997) (recognizes well‑established right to bodily integrity)
- Pagán v. Calderón, 448 F.3d 16 (1st Cir. 2006) (substantive due process shock‑the‑conscience framework)
- Lipsett v. Univ. of P.R., 864 F.2d 881 (1st Cir. 1988) (applies Title VII/Title IX hostile‑environment framework to equal‑protection sexual‑harassment claims)
- Oncale v. Sundowner Offshore Servs., 523 U.S. 75 (1998) (sex‑based harassment may be inferred from context and implied proposals)
- Meritor Sav. Bank v. Vinson, 477 U.S. 57 (1986) (adopts severe or pervasive standard for Title VII hostile‑environment claims)
- Gebser v. Lago Vista Indep. Sch. Dist., 524 U.S. 274 (1998) (Title IX deliberate indifference/actual‑notice framework)
- Davis ex rel. LaShonda D. v. Monroe Cnty. Bd. of Educ., 526 U.S. 629 (1999) (Title IX liability requires deliberate indifference to harassment so severe, pervasive, and objectively offensive that it denies equal access)
- Monell v. N.Y. City Dep't of Soc. Servs., 436 U.S. 658 (1978) (municipal liability under § 1983 requires an official policy or custom causing the constitutional violation)
- Harlow v. Fitzgerald, 457 U.S. 800 (1982) (standard for qualified immunity: clearly established law)
- Hayut v. State Univ. of N.Y., 352 F.3d 733 (2d Cir. 2003) (professor’s sexually charged conduct could support hostile‑environment claim)