Palm Beach County School Board v. Janie Doe 1Annotate this Case
Respondents - four female students and their parents - filed a complaint against their teacher and the Palm Beach County School Board, alleging that the teacher sexually molested the children and that the School Board was negligent. Respondents later filed a third amended complaint adding a claim for violation of Title IX of the Education Amendments of 1972. The School Board filed a motion to dismiss the Title IX claim, arguing that it was barred by the statute of limitations because it id not relate back to the filing of the original complaint. The trial court agreed and dismissed the claim. The Fourth District Court of Appeal reversed, finding that the Title IX claim did, in fact, relate back to the original negligence claims. The Supreme Court approved of the Fourth District’s decision and disapproved the line of cases establishing a bright-line rule that an amendment asserting a new cause of action cannot relate back to the filing of the original complaint, holding that Respondents’ Title IX claim did not relate back to Respondents’ original pleading.