Nov. 8—CHEYENNE — The federal question of a school district’s responsibility to investigate inappropriate student-teacher relationships was recently put back on the table as an appeals court sent a lawsuit against Laramie County School District 1 back to Wyoming.
The question is whether a school district must receive an official complaint from the alleged victim before choosing to investigate reports of sexual assault by a teacher.
LCSD1 was sued by a former student in March 2020 for failing to investigate the inappropriate relationship between her and her former seventh-grade math teacher, Juan Meza. The former student, who later became Meza’s adopted teenage daughter, was sexually abused by him for years before she filed a report with the Cheyenne Police Department in May 2017, according to court documents.
Meza was sentenced up to 40 years in prison in January 2019 after he was convicted of first-degree sexual abuse of a minor in Laramie County District Court. The student filed a lawsuit against LCSD1 in the U.S. District Court of Wyoming, claiming the school district was aware of the inappropriate interactions between her and Meza, but “deliberately” chose not to investigate.
U.S. District Judge Alan B. Johnson concluded that LCSD1 “was not deliberately indifferent” because it had no actual notice that “Mr. Meza posed a substantial risk of abuse before” the former student filed the report to police, according to recent federal court documents. This decision was appealed by the plaintiff to the 10th Circuit U.S. Court of Appeals.
The three appellate court judges reversed the district court’s order on Tuesday and sent the case back for further proceedings.
“It’s a huge victory for the plaintiff … who was subjected to years of sexual abuse by her math teacher,” wrote Anna Olson, the student’s attorney, in an email to the Wyoming Tribune Eagle. “Now, she can present her case to the jury.”
The lawsuit against LCSD1 complained that the school district, which receives federal funding, violated the former student’s rights under Title IX of the Education Amendments of 1972.
Several reports presented in the case claimed that teachers and principals at Johnson Junior High School were told of or witnessed “increasingly inappropriate and flirty” behavior from Meza toward the student, which began in 2014. Although school principals “denied or did not recall ever receiving these reports,” according to court documents, a few teachers testified about reporting these incidents.
Shannon Hall, a Johnson Junior High teacher, testified that she saw the student in Meza’s classroom before school nearly a dozen times and occasionally after school, as well. Other reports included students observing weird behaviors from Meza toward the student, such as drinking from the same soda can, according to documents.
In the original 2020 lawsuit, the student, who the WTE has decided not to identify, since she was a victim of sexual abuse, filed three claims against LCSD1:
— LCSD1 violated Title IX based on knowledge of and failure to address Meza’s conduct
— LCSD1 violated the Equal Protection Clause under the 14th Amendment
— LCSD1 violated the student’s substantive due process under the 14th Amendment
LCSD1 claimed in its motion for summary judgment that “a school cannot be deliberately indifferent” to abusive behavior from a teacher without “sufficient notice of abuse.” The plaintiff appealed the district court’s order after LCSD1’s motion was upheld, arguing the school did, in fact, have “substantive notice” before the police report.
Chief Judge Jerome Holmes wrote in his 50-page opinion that in order to determine a school district had “knowledge of a substantial risk of abuse,” the court should examine reports in totality. In his reference to Escue v. Northern Oklahoma College, the federal judge noted a school district was properly notified of a teacher’s sexual abuse toward a student “based on the student’s report to the principal.”
Holmes focused on defining what is “actual knowledge of a substantial risk of abuse,” and agreed with the plaintiff that the lower court “erred” in its decision.
“We agree with (the plaintiff) that the district court erred in finding no genuine dispute as to whether LCSD1 had actual knowledge of discrimination because it failed to draw all reasonable inferences in (plaintiff’s) favor and failed to credit certain evidence,” Holmes wrote in the opinion.
In conclusion, Holmes argued the district court’s decision was “erroneous” because it failed to “address deliberate indifference before LCSD1 learned of (plaintiff’s) police report” before arriving at a conclusion that the school district lacked “actual notice.”
No information was available about when the case will be heard in U.S. District Court.
Hannah Shields is the Wyoming Tribune Eagle’s state government reporter. She can be reached at 307-633-3167 or [email protected]. You can follow her on X @happyfeet004.
Amanda Smith is a dedicated U.S. correspondent with a passion for uncovering the stories that shape the nation. With a background in political science, she provides in-depth analysis and insightful commentary on domestic affairs, ensuring readers are well-informed about the latest developments across the United States.
