- Date:
- May 24, 1999
- Location:
- Georgia
- United States
Davis v. Monroe County Board of Education
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What is Davis v. Monroe County Board of Education?
Davis v. Monroe County Board of Education is a 1999 U.S. Supreme Court case. The Court ruled (5–4) that, under Title IX of the Federal Education Amendments (1972), school boards are liable for failing to stop student-on-student sexual harassment under certain circumstances.
The case centered on LaShonda Davis, a fifth grader who was sexually harassed by a classmate. Davis's mother brought a lawsuit under Title IX, alleging that school officials knew of the harassment but did nothing to prevent it. The Supreme Court held that school boards are liable when officials are deliberately indifferent to severe, pervasive, and objectively offensive sexual harassment that deprives victims of equal access to educational opportunities.
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What issue was the main focus of this court case?
The central issue in Davis v. Monroe County Board of Education was whether school boards could be held liable under Title IX of the Federal Education Amendments (1972) for failing to prevent student-on-student sexual harassment.
The case originated when LaShonda Davis, a fifth-grade student, was allegedly sexually harassed by a classmate over six months. Davis's reports to teachers and her mother's calls to school officials went unheeded, and no disciplinary action was taken. Subsequently, a lawsuit was filed, arguing that the school board should be responsible for the continuous sexual harassment.
The Supreme Court ruled (5–4) that school boards are indeed liable if officials are deliberately indifferent to severe, pervasive, and objectively offensive sexual harassment, of which they have actual knowledge, and that deprives victims of equal access to educational opportunities.
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Who were the people or groups involved in this case?
In Davis v. Monroe County Board of Education, LaShonda Davis, a fifth-grader, was allegedly sexually harassed by a classmate, G.F. Davis's mother brought a lawsuit under Title IX against the Monroe County Board of Education and school officials, arguing they failed to stop the harassment. The case reached the U.S. Supreme Court after being rejected by a federal district court and the Eleventh Circuit Court of Appeals. The Supreme Court reversed the Eleventh Circuit's decision, ruling that school boards can be liable for student-on-student sexual harassment if officials are deliberately indifferent to known harassment that is severe, pervasive, and objectively offensive, thereby depriving victims of equal access to educational opportunities.
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What was the argument made by the student in this case?
LaShonda Davis, a fifth-grader, was the student involved in Davis v. Monroe County Board of Education. Davis contended that G.F., a classmate, sexually harassed her over six months. The harassment included attempts to fondle her, offensive language, and unwanted touching. Davis reported these incidents to teachers and her mother contacted the school, but no action was taken, and her request to change seats was initially denied.
Davis's mother filed a lawsuit under Title IX, arguing that the school board should be liable because school officials knew about the harassment but did nothing to stop it. The suit sought relief and damages for the continuous sexual harassment her daughter experienced.
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How did the Supreme Court rule in Davis v. Monroe County Board of Education?
In Davis v. Monroe County Board of Education, the Supreme Court ruled (5–4) on May 24, 1999, that school boards can be held liable under Title IX of the Federal Education Amendments (1972) if they fail to stop student-on-student sexual harassment under certain conditions.
The case involved LaShonda Davis, a fifth grader who was allegedly sexually harassed by a classmate. The Court stated school boards are liable when officials are deliberately indifferent to known sexual harassment that is so severe, pervasive, and objectively offensive that it deprives victims of equal access to educational opportunities or benefits. The harassment must have a systemic effect, denying the victim equal access to education. The Supreme Court overturned the decision of the Eleventh Circuit and sent the case back for reconsideration.
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Why is this case important for schools and how they handle harassment?
Davis v. Monroe County Board of Education is important for schools because it established that school boards can be held liable under Title IX of the Federal Education Amendments (1972) if they fail to stop student-on-student sexual harassment. To be liable, officials must have actual knowledge of the harassment, and be deliberately indifferent to it. Also, the harassment must be so severe, pervasive, and objectively offensive that it deprives victims of equal access to educational opportunities. This ruling set a legal precedent for how schools handle harassment.
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Davis v. Monroe County Board of Education, case in which the U.S. Supreme Court on May 24, 1999, ruled (5–4) that, under Title IX of the Federal Education Amendments (1972), school boards are liable for failing to stop student-on-student sexual harassment under certain circumstances.
The case centred on LaShonda Davis, a fifth grader in Monroe county, Georgia. Over a six-month period in 1992–93, a classmate identified as G.F. allegedly sexually harassed or abused Davis (and others) by attempting to fondle her, touching her, and directing offensive language toward her. An example of G.F.’s behaviour occurred in December 1992, when he allegedly tried to touch Davis’s breasts and genital area, telling her, “I want to get in bed with you” and “I want to feel your boobs.” Davis repeatedly reported G.F. to her teachers, and her mother called the teacher and the principal to see what could be done to protect her daughter. The requests for protection went unfulfilled, and no disciplinary action was taken. Even Davis’s request to change seats because G.F. sat next to her was not allowed until after she had complained for more than three months. In May 1993 G.F. was charged with sexual battery and pled guilty.
In 1994 Davis’s mother brought a lawsuit under Title IX, which states that
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no person…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.
The suit, which named the school board and several school officials as respondents, sought injunctive relief and compensatory damages for the alleged continuous sexual harassment of her daughter by a classmate. The suit contended that school officials knew of the harassment but failed to take any meaningful action to prevent it from continuing. The case started in a federal district court in Georgia and went on to the Eleventh Circuit Court of Appeals, with both rejecting the notion of board liability for student-on-student sexual harassment.
On January 12, 1999, the case was argued before the U.S. Supreme Court. Writing for the majority, Justice Sandra Day O’Connor held that school boards are liable when officials are
deliberately indifferent to sexual harassment, of which they have actual knowledge, that harassment is so severe, pervasive, and objectively offensive that it can be said to deprive the victims of access to the educational opportunities or benefits provided by the school.
Moreover, the court also required that the harassment be “serious enough to have the systemic effect of denying the victim equal access to an education program or activity.” According to the majority, a systemic effect means that it is unlikely that a single act of one-on-one peer harassment would meet the requisite level of systemic effect. The Supreme Court thus overturned the decision of the Eleventh Circuit and remanded the case.
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