T. v. Oakley Union Elementary School District

Background

C. T., a minor represented by guardians ad litem, sued Oakley Union Elementary School District. She alleged that another student, identified as A.A., engaged in sexual misconduct against her at her family’s home in October 2021. She reported the incident to a district school psychologist, but alleged that the psychologist did not take sufficient follow-up action.

C. T. also alleged that A.A. and his friends later harassed her at school and through electronic messages. The alleged conduct included sexually derogatory name-calling, A.A.’s placement in a class with C. T. after she had transferred classes, threats, a physical attack by a student identified as A.M., and a later incident in which another student tripped her with a towel. C. T. alleged that Oakley failed to respond appropriately. She later transferred to another middle school within the district and, at the time of filing, attended high school in a different district.

The complaint asserted four claims: gender discrimination and hostile environment under Title IX; gender discrimination and hostile environment under California Education Code section 220; negligence; and negligent training and supervision. Oakley moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint alleges enough facts to state a legally recognized claim.

Title IX and California Education Code Claims

The court analyzed the Title IX and section 220 claims together because courts interpret section 220 consistently with Title IX. For a damages claim based on student-on-student sexual harassment, the plaintiff must allege, among other things, that the school controlled the harasser and the setting, the harassment was severe, pervasive, and objectively offensive enough to deny equal access to education, an authorized official had actual knowledge, the school acted with deliberate indifference, and that deliberate indifference caused the harassment or vulnerability to it.

The court concluded that the allegations, considered at the pleading stage, were sufficient to support an inference that the overall pattern of conduct was severe, pervasive, and objectively offensive. The court considered the off-campus sexual misconduct as part of the surrounding circumstances relevant to the on-campus harassment, even though C. T. had not adequately alleged that Oakley controlled the off-campus incident or the electronic group chats.

The court nevertheless found that C. T. had not adequately pleaded deliberate indifference. Although Oakley did not dispute that the school psychologist had authority and actual knowledge of the October 2021 incident, C. T. did not identify legal authority requiring the psychologist to take a particular action in response to an incident that occurred outside the school’s control and outside an education program or activity. The court also noted that the school reprimanded students involved in the January 2022 classroom name-calling and granted C. T.’s request to change classes.

The complaint did not allege that an appropriate Oakley official knew that A.A. had later been placed in C. T.’s new class or knew that the placement caused her serious distress. It also did not show that Oakley had prior notice of the April 2023 attack or that its response to that attack was unreasonable. The allegations likewise did not support an inference that Oakley’s conduct caused or contributed to the June 2023 tripping incident. The court therefore held that C. T. had not pleaded sufficient facts for either the Title IX claim or the section 220 claim.

Negligence Claims

C. T. conceded that the negligence-based claims were limited to incidents after March 28, 2023. The court therefore considered only the April 2023 physical attack and the June 2023 tripping incident.

The court held that C. T. identified a statutory basis for liability by citing California Government Code section 815.2. But the complaint did not allege with sufficient particularity how the April and June incidents were foreseeable injuries that Oakley should have prevented. Knowledge of the 2021 off-campus misconduct did not reasonably put Oakley on notice that A.A.’s friends would physically attack C. T. at school more than a year later, particularly after C. T. and A.A. no longer attended the same school.

The negligent supervision claim also failed because C. T. did not specifically identify the acts or omissions that caused Oakley to fail to supervise or train its personnel. The court additionally found that the complaint did not allege that Oakley personnel could reasonably have foreseen and prevented the April and June 2023 incidents.

Disposition

Judge Donna M. Ryu granted Oakley’s motion to dismiss C. T.’s claims. The court dismissed the claims with leave to amend and granted permission to file an amended complaint by November 12, 2025. The opinion does not state that the dismissal was with or without prejudice.