KC v. Mayo, No. 19-3010 (8th Cir. 2020)
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The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the District and three individual school officials in an action brought by a student, alleging claims of sexual abuse and harassment by a teacher and coach, Johnna Feazell.
Where, as here, a complaint involves allegations against school officials brought under both Title IX and 42 U.S.C. 1983, this court has held that an official in these circumstances must have actual notice of the alleged sexual harassment or sexual abuse by a school employee to meet the standard for liability. In this case, a searching review of the summary judgment record reveals no evidence to indicate school officials had actual notice of sexual harassment or abuse by Feazell prior to the events at issue. Rather, when plaintiff's mother met with the school principal with the cell phone containing text messages evidencing a sexual relationship between plaintiff and Feazell, school officials took immediate action by contacting law enforcement and placing Feazell on administrative leave. Therefore, the district court did not improperly weigh the evidence and the summary judgment record established that no genuine dispute exists as to whether the District or any school official had actual notice of sexual abuse or harassment prior to October 13, 2014.
Court Description: [Erickson, Author, with Loken and Shepherd, Circuit Judges] Civil case - Civil rights. When, as here, a complaint involves allegations against school officials brought under both Title IX and Section 1983, this court has held that an official in these circumstances must have actual notice of the alleged sexual harassment or sexual abuse by a school employee to meet the standard for liability; viewing the facts in the light most favorable to plaintiff, her claims cannot survive summary judgment because the facts are insufficient to support a finding that the school officials had actual notice of sexual abuse or harassment by a teacher prior to October 14, 2014, when plaintiff's mother met with school officials and provided them with a cell phone containing text messages evidencing a sexual relationship between the teacher and plaintiff; at that point, school officials took immediate action, contacting the police and placing the teacher on administrative leave; thus, actual notice cannot be assigned to the district or any school official before October 14, 2014, and there is no liability for their actions prior to that date. [ December 18, 2020 ]
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