Doe v. Fort Zumwalt R-II School District, No. 18-2093 (8th Cir. 2019)
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Plaintiff, on behalf of his minor sons and a class of current and former students of the school district who were videotaped in the nude by Defendant Hansen, filed suit under 42 U.S.C. 1983 against several district defendants. The district court entered default judgment against Hansen in his individual capacity and summary judgment for the district defendants.
The Eighth Circuit affirmed, holding that the district's failure to provide more supervision and training did not rise to the level of a constitutional violation where plaintiff presented no evidence of a pattern of misconduct that would alert the district that its training and supervision were insufficient to prevent Hansen's conduct, and, without notice, the district's failure to provide more training or supervision was not deliberately indifferent. The court also held that plaintiff waived his Child Abuse Victims Rights Act of 1986 (CAVRA) claim because CAVRA is not a predicate statutory violation for a section 1983 claim.
Court Description: Benton, Author, with Melloy and Kelly, Circuit Judges] Civil case - Section 1983. In this action by a class of current and former students of Fort Zumwalt School District who were videotaped in the nude at the district's overnight camp by defendant Hansen, a teacher at the school, plaintiff Doe failed to show the district had reason to believe its training and supervision were inadequate to prevent Hansen's conduct; without notice, the district's failure to provide more supervision or training was not deliberately indifferent; nor was the risk so obvious that the failure to provide more training or supervision constituted deliberate indifference. [ April 10, 2019
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