N. R. Doe v. St. Francis Sch. Dist., No. 12-1039 (7th Cir. 2012)Annotate this Case
A suit on behalf of a 14-year-old, eighth grade boy alleged that the failure of the public school district to prevent sexual abuse by a female teacher violated the student’s rights under Title IX of the federal Education Amendments Act of 1972, 20 U.S.C. 1681, and constituted negligent infliction of emotional distress under Wisconsin law. The district court granted summary judgment in favor of the school district; claims against the teacher remain pending. The Seventh Circuit affirmed. In a private suit under Title IX, a school district cannot be held liable on the ground of respondeat superior for an employee’s violation absent proof of actual notice and deliberate indifference. That other teachers suspected improper conduct and administrators investigated and accepted the teacher’s denials does not establish knowledge or deliberate indifference.