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Keywords

plaintiffappealtrialverdictdiscriminationharassmentobjectionjury instructions
appealverdictwilljury instructions

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Bostic v. Smyrna School Dist., 418 F.3d 355, 200 Ed. Law Rep. 573

Facts

In the spring of 1999, Jennifer Bostic, a fifteen-year-old sophomore at Smyrna High School, developed a sexual relationship with her track coach, John Smith. This relationship included numerous sexual encounters and became a topic of discussion among students, eventually reaching the school's principal and assistant principal. Bostic's parents expressed concerns about the relationship, leading to meetings with school officials. Despite warnings to Smith about his conduct, the school administration's response was deemed insufficient, and the relationship continued until Smith was later arrested for unrelated charges involving other students.

In the spring of 1999, Bostic was fifteen years old, a sophomore at Smyrna High School, and a member of the school's track team, which was coached by Smith. A sexual relationship developed between Bostic and Smith. The relationship included numerous sexual encounters during and after the school day, both on and off campus, and continued for approximately one year.

Issue

Did the district court err in its jury instructions regarding 'actual notice' and 'appropriate official' under Title IX?

Did the district court err in its jury instructions regarding 'actual notice' and 'appropriate official' under Title IX?

Rule

Under Title IX, an educational institution is liable for sexual harassment if an 'appropriate person' with actual notice of discrimination fails to respond with deliberate indifference. An 'appropriate person' is defined as an official with authority to address discrimination and institute corrective measures. Actual notice requires knowledge of facts indicating substantial danger to a student, and the response must reflect a decision not to remedy the violation.

Analysis

The court applied a plain error standard to review the jury instructions, noting that the plaintiffs did not clearly object to the instructions during the trial. The court found that the jury instruction on actual notice did not impose a higher standard than required, as it informed the jury that actual notice could be established if an appropriate person had knowledge of facts indicating substantial danger. The court also determined that the principal and assistant principal could not be deemed appropriate persons solely based on their positions, as the evidence needed to show they had actual knowledge of the misconduct.

On plain error review of challenged jury instructions, Court of Appeals will overturn a verdict only when the error is fundamental and highly prejudicial or when the instructions are such that the jury is without adequate guidance on a fundamental question and failure to consider the error would result in a miscarriage of justice. Fed.Rules Civ.Proc.Rule 51(d)(2), 28 U.S.C.A.

Conclusion

The Court of Appeals affirmed the district court's judgment, concluding that the jury instructions were appropriate and did not constitute plain error.

Based upon the foregoing, we affirm the judgment of the District Court.

Who won?

The prevailing party in this case was the Smyrna School District and its officials, as the jury found in their favor on all claims except against the coach, John Smith. The court upheld the jury's verdict, emphasizing that the plaintiffs failed to demonstrate that the school officials had actual notice of the misconduct or that their responses were deliberately indifferent. The court's analysis highlighted the importance of clear objections to jury instructions, which the plaintiffs did not adequately provide.

The prevailing party in this case was the Smyrna School District and its officials, as the jury found in their favor on all claims except against the coach, John Smith.

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