Doe v. Mt. Diablo Unified School District

Background

The defendant, Mt. Diablo Unified School District, moved for summary judgment on the plaintiffs’ Title IX and negligence claims. Summary judgment is a ruling without a trial when the record shows that no reasonable jury could find for the opposing party on a claim.

The opinion discusses alleged misconduct by Gonzalez. The plaintiffs’ negligence claim included negligent hiring and negligent supervision theories.

Rulings

The court granted the motion for summary judgment as to the Title IX claim. Under the governing standard, the record had to support a finding that a District official with authority to take corrective action had actual knowledge of Gonzalez’s misconduct and acted with deliberate indifference. The court found no evidence from which a reasonable jury could make that finding.

The court denied the motion for summary judgment as to the negligence claim. On negligent hiring, Gonzalez’s personnel file from a prior job documented two sexual-nature misconduct incidents. The court concluded that a reasonable jury could find that the District had to make reasonable efforts to discover disciplinary records when hiring teachers to care for a vulnerable student population, and that its investigation was inadequate. A jury could also find that discovering those incidents would have alerted the District and its employees that Gonzalez posed a threat to student safety.

On negligent supervision, the court concluded that a reasonable jury could find it negligent to place Gonzalez in a physically remote classroom where he could be alone and undisturbed with a student during and immediately after the school day. The court also noted testimony that the distance from the classroom to the principal’s office led the principal to observe Gonzalez less frequently than other teachers. The court stated that a jury could find the placement negligent because of Gonzalez’s prior misconduct and, even without considering that misconduct, because of the students’ particular vulnerability.

Disposition

The court granted in part and denied in part the District’s motion for summary judgment: it granted the motion as to the Title IX claim and denied it as to the negligence claim.