Davis v. Monroe County Board of Education
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Introduction
Since its addition to the United States Constitution, the Fourteenth Amendment was intended to uphold the principle that no State shall “deny to any person within its jurisdiction the equal protection of the laws.” Title IX, specifically, is an extension of said amendment, and has been interpreted to include prohibiting sex discrimination in educational or federally financed institutions. The case of Davis v. Monroe County Board of Education challenged Justices in determining how far Title IX’s protection extends, as it does not explicitly address sexual harassment in schools.
Facts
Fifth grader LaShonda Davis was faced with sexual harassment from a classmate on multiple occasions at Hubbard Elementary School in Monroe County, Georgia. The victim reported the assailant’s inappropriate physical and verbal advancements to her mother and school teacher. Despite the principal having knowledge of the incidents, Davis continued to endure the trauma of having her classmate rub his body against hers and exclaim vulgar phrases such as “I want to get in bed with you.” Davis made the harassment clear to other school administrators, as the instances became more prevalent. However, she was not permitted to change classroom seats and be separated from the assailant. Furthermore, the assailant did not face any school-instituted consequences, as the principal called out Davis for being “the only one complaining,” despite the fact that other girls expressed similar sentiments about the inappropriate behavior of their classmate. The sexual harassment reached an extreme in which LaShonda contemplated suicide; her parents thus made the decision to file a lawsuit against the Board, the school district superintendent, and the school principal on the basis that the educational institution violated Title IX by not taking action to prevent sex discrimination in the classroom.
Legal Background
Davis’ parents filed a lawsuit in the United States District Court for the Middle District of Georgia under Title IX, seeking monetary compensation and injunctive relief. They argued that the sexual advances by the assailant interfered with Davis’ ability to learn materials in the classroom, and that the “deliberate indifference by the Defendants . . . created an intimidating, hostile, offensive, and abusive school environment.” The District Court, however, sided with the defendants’ citation of section 12(b)(6) of the Federal Rule of Civil Procedure, stating that there was no claim that provided a foundation for relief to be given to the victim, and that Title IX does not extend to this scenario. The Court of the Appeals for the Eleventh Circuit also rejected Davis’ case, arguing that Title IX lacks specificity in declaring how actions should be taken by school administrators in sexual harassment cases. Davis appealed and the Supreme Court granted certiorari to hear the case.
Holding & Reasoning
In a 5-4 decision with a majority opinion written by Sandra Day O’Connor, the Supreme Court concluded that Title IX provided sufficient reasoning that the Board, school district superintendent, and school principal should be held responsible for the conscious indifference and inaction exhibited during Davis’ harassment. O’Connor declared that educators must be held responsible when the harassment is so horrific that a student is not able to “access the educational opportunities or benefits provided by the school.” Furthermore, Supreme Court Justices applied the Spending Clause, associated with Title IX, to reinforce their decision in the case at bar that educational institutions who have received funding from Congress must face legal consequences for instances like student-to-student sexual harassment. Davis and her assailant were both under the “operation” of the school district, and the defendants have the ability and responsibility to exercise authority over educators and students.
The dissenting Justices, led by Justice Anthony M. Kennedy, argued that federal laws should not interfere with local school administrations and expressed concern regarding excessive involvement in determining “day-to-day classroom logistics and interactions.” They also viewed the case through the lens of federal overreach into state and local decision making.
Although Title IX places school administrators in difficult positions regarding involvement in students’ lives, previous court cases involving Title IX such as Franklin v. Gwinnett County Public Schools and Gebser v. Lago Vista serve as precedents for Congress to evaluate the extent to which school districts are responsible. In Franklin v. Gwinnett County Public Schools, a high school teacher sexually harassed a student, and in a unanimous decision, the Supreme Court ruled that the victim was entitled to monetary relief under Title IX. In Gebser v. Lago Vista, a teacher and student engaged in sexual activity, and the student sued the school district for damages. Although the Supreme Court ruled in favor of the Lago Vista school district, Justices detailed specific criteria for determining when schools should be liable for Title IX violations. These cases in particular provide previous precedents for Davis to receive monetary compensation and relief, in addition to upholding the principle that educational institutions should be held accountable for sexual harassment in classrooms.
Analysis
The key legal question underpinning this case is whether Title IX covers sexual harassment. Per Title IX, “No person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving federal financial assistance.” In Davis v. Monroe County Board of Education, the student’s ability to thrive in the school’s learning environment was inhibited by her assailant’s sexual advances. There is a range of activity that can fall under the definition of sexual harassment, so it is understandable that the dissenting Justices were cautious about the Supreme Court drawing a line about what constitutes actions that affect one’s ability to learn. If extreme sexual harassment was not included in the scope of Title IX, a number of cases, including the one at bar, would unfairly put sexually harassed students at a disadvantage in schools. Davis v. Monroe County Board of Education did require the Court to determine what is or what is not legally acceptable sexual behavior. Dissenting Justices warned of the Court’s involvement in arbitrating “routine problems of adolescence.” Although the language used by the dissenting Justices is dismissive of the severity of sexual assault, it does raise the question of whether the Court should be involved in drawing the line of what constitutes an inhibition of a student’s ability to learn.
The case also opened the door for courts to determine how far the learning institution’s responsibility for sexual harassment extends, such as in the case of J.K. v. Arizona Board of Regents in 2008. Arizona State University was determined to be responsible for an expelled student’s actions, even after he was no longer a member of the school community.
The case law in J.K. v. Arizona Board of Regents associated with Davis v. Monroe County Board of Education involved the court having to determine what constitutes sexual harassment and the extent to which schools are responsible. The ruling of Davis v. Monroe County Board of Education ultimately set a precedent for Title IX covering sexual harassment; it has thus enabled a safer learning environment and provided legal protection for students facing harassment.