Summary of Ray v. Antioch Unified School District (2000)
Facts: The plaintiff was a minor who was constantly verbally abused by his classmates because they considered him to be a homosexual. A boy by the name is Jonathon Carr especially gave the plaintiff hard time. The plaintiff reported the abuse he was taking to his teachers and the school officials, but no action against Carr and other students was taken. One day, Carr assaulted the plaintiff while the plaintiff was walking home and this assault resulted in severe injuries to the plaintiff. Now the plaintiff’s mother argues that the assault and the constant abuse has made the plaintiff so mentally upset that he can not take the benefits of education. The defendants (school district, school officials, and parents of Carr) argue that the plaintiff can not state a claim under Title IX because Title IX does not prohibit discrimination on the basis of ‘homosexuality or transsexualism’.
Issue: 1. Can the defendant state a claim under Title IX if he was subject to ‘same-sex’ harassment? 2. Does the plaintiff have high chances of success under Title IX?
Holding: 1. Yes 2. Yes
Key Facts: In Davis v. Monroe, the Supreme Court has ruled that in order for the state funded educational institutions to be liable under Title IX, they must be “(1) deliberately indifferent, (2) to sexual harassment, (3) of which they have actual knowledge, (4) that is so severe, pervasive, and objectively offensive, (5) that it can be said to deprive the victims of access to the educational opportunities or benefits provided by the school.” The court also ruled that mere teasing, even if it involves the subject of sex, can not be considered severe, pervasive and objectively offensive harassment.
Legal Reasoning: The court used Oncale v. Sundowner to rule that ‘same-sex’ harassment can be considered under Title IX. The court further ruled that since the plaintiff had reported the abusive incidents to the school officials and the school officials failed to take action, it shows that the defendants were indifferent to plaintiff’s complaints (#1 of Davis Requirement). Also, since the students and Carr abused plaintiff because they considered him to be a homosexual, their actions can be considered sexual harassment (#2). Also, since the plaintiff reported the incidents to the school officials, it shows that the school officials had the actual knowledge of the abuse (#3). The plaintiff was constantly threatened and he was actually assaulted by Carr, which makes the harassment ‘severe, pervasive, and objectively offensive’ (#4). Furthermore, since the the assault incident and the constant abuse has made the plaintiff physically and mentally fearful of his school, he is being deprived of educational benefits (#5). So the court ruled that since the plaintiff meets all the Davis requirements, he has a valid claim under Title IX and the defendant’s Motion was denied.