Wadsworth v. MSAD 40/RSU 40

Wadsworth v. MSAD 40/RSU 40

Public Justice filed an amicus brief in this First Circuit appeal in support of the Plaintiff, Adrianna Wadsworth, who was sexually harassed as a high school student by her principal.

Beginning in 2016, Medomak Valley High School principal Andrew Cavanaugh groomed and sexually harassed student Adrianna Wadsworth. At the time, Adrianna was a vulnerable teenager with a turbulent home life. When the two first met, Principal Cavanaugh held himself out as someone who could help Adrianna. Around the same time, he began routinely sexually harassing her over text messages and in person. Nearly every day, he commented on what Adrianna was wearing, said she was pretty, or told her she looked nice. He would call her pet names, including “cupcake” and “princess.” He routinely gave her gifts, including cash. He asked for pictures of her in a bathing suit while she was at the beach. He also took her to a doctor’s appointment and suggested that she get on birth control. He invited her to move in with him numerous times and allowed her to drive his car. Multiple school staff, including two assistant principals, witnessed or received complaints about some of Cavanaugh’s inappropriate conduct toward Adrianna, and Adrianna also told the school social worker and an assistant principal that she was uncomfortable with the principal’s comments.

Adrianna sued the school district, Principal Cavanaugh, and the social worker for violations of Title IX, the Equal Protection Clause of the U.S. Constitution, and state law. The school district argued that the assistant principal was not an “appropriate person” high enough in the school’s hierarchy to address Cavanaugh’s harassment, so notice to her was not notice to the school. Principal Cavanaugh argued that he was entitled to qualified immunity. The district court granted summary judgment on all of Adrianna’s claims against the school district and on the constitutional claims against the individual defendants. It held that the assistant principal was an appropriate person, but she did not have “actual knowledge” of the harassment, so the school could not be liable. It also held that Principal Cavanaugh was entitled to qualified immunity because, in the court’s view, it was not clear that his sexual harassment violated the Constitution. Adrianna appealed.

On December 7, 2023, Public Justice filed an amicus brief in support of Adrianna. The brief argues that the district court was correct in holding that school administrators can be appropriate persons under Title IX even where their supervisor is the harasser; that the assistant principals’ willful blindness to the harassment satisfies Title IX’s “actual notice”; and that it is clearly established that verbal sexual harassment by school staff violates the Equal Protection Clause of the Fourteenth Amendment, such that Principal Cavanaugh was not entitled to qualified immunity.

We await the First Circuit’s ruling in the case.

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