Jane Doe v. Willits Unified School Distric

MEMORANDUM

Jane Doe, through her guardian ad litem, Kristen D., appeals the district court’s summary judgment in favor of Willits Unified School District, Willits Charter School, and Sally Rulison, the Director of the school (collectively “Willits”). Doe’s action stems from a sexual relationship between Doe and her high school math and science teacher. After the relationship was made public, Doe filed suit alleging claims under 42 U.S.C. § 1983 and Title IX of the Education Amendments of 1972, 20 U.S.C. § 1681 (a), as well as under state law for negligent hiring and supervision. We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we affirm.

Although Doe advances multiple grounds for relief, her appeal fails because she is unable to meet a key threshold requirement: that the school’s response to the alleged injuries was deliberately indifferent. Damages under Title IX are available only if an official with authority to address the alleged discrimination and institute corrective measures has actual knowledge of the discrimination and fails to adequately respond—i.e., acts with deliberate indifference. Gebser v. Lago Vista Indep. Sch. Dist., 524 U.S. 274, 290 , 118 S.Ct. 1989 ,…