Zeno v. Pine Plains Central School District
2012 U.S. App. LEXIS 24833
| 2d Cir. | 2012Background
- Anthony Zeno transferred to SMHS in Pine Plains, NY, where he faced persistent racial harassment for three and a half years; the District was sued under Title VI for deliberate indifference and a jury awarded $1.25 million in damages.
- District employees and administrators were aware of harassment reports from faculty, Zeno, and third parties, but remediation was limited, delayed, or non-discriminatory in focus.
- The District declined to implement a free shadow or racially targeted training offered by local civil rights groups, and only later provided minimal, non-specialized programs.
- Anthony ultimately earned an IEP diploma instead of a Regents diploma, raising concerns about the educational benefits denied by the hostile environment.
- During trial, the District sought judgment as a matter of law and, after jury verdict, the court granted remittitur to $1 million; on appeal, the district court’s rulings were affirmed on liability and damages.
- The court applied Davis v. Monroe County Bd. of Educ framework to assess deliberate indifference and affirmed that the District’s responses were clearly unreasonable in light of known circumstances.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the District was deliberately indifferent to student harassment under Title VI | Zeno; the harassment was severe and pervasive, with actual knowledge by the District | Pine Plains contends responses were adequate and not deliberately indifferent | Yes; district court correctly denied judgment as a matter of law |
| Whether the damages award for Title VI harassment was appropriate | The $1 million (remitted from $1.25M) reflects substantial emotional and educational harm | Damages excessive; potential examples in other cases set lower figures | Within the range of permissible decisions; remittitur not abused |
| Whether the District’s knowledge, control, and response support liability | District had actual knowledge, substantial control, and inadequate remedial actions | Responses were prompt and non-deliberately indifferent in light of circumstances | Yes; deliberate indifference established |
Key Cases Cited
- Davis v. Monroe Cnty. Bd. of Educ., 526 U.S. 629 (U.S. 1999) (deliberate indifference framework for student-on-student harassment)
- Gebser v. Lago Vista Indep. Sch. Dist., 524 U.S. 274 (U.S. 1998) (teacher-on-student harassment; actual knowledge and response required)
- Hayut v. State Univ. of N.Y., 352 F.3d 733 (2d Cir. 2003) (disparate hostile environment in higher education context)
- Ismail v. Cohen, 899 F.2d 183 (2d Cir. 1990) (damages framework in Title VI/Title IX context; deference to jury awards)
- Manganiello v. City of New York, 612 F.3d 149 (2d Cir. 2010) (standard for reviewing remittitur and damages within range)