K.T. v. Culver-Stockton College
K.T. v. Culver-Stockton College, 865 F.3d 1054 (2017)
Winning Party
Culver-Stockton College
Key Issue
Title IX student-on-student harassment claim
Case Type
CIVIL
Facts
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The College allegedly only canceled a scheduled conference with K.T. and her parents in response to the report.
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K.T. alleges she was physically and sexually assaulted by a fraternity member who was a student at Culver-Stockton College.
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K.T. alleged that Culver-Stockton was deliberately indifferent by failing to adopt practices to prevent sexual assault and also failing to investigate and offer medical services to K.T. after it received reports of the alleged incident.
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K.T.'s complaint stated that her assault allegations were reported to Culver-Stockton one to two days after the fraternity party.
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While visiting, K.T. attended a party at an on-campus fraternity house where she was allegedly served alcohol.
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K.T.'s complaint is limited to an allegation of a single sexual assault.
•
The incident was reported to College authorities the same weekend of the party.
•
K.T., a sixteen-year-old high school junior, was invited to visit Culver-Stockton College as a potential recruit for the women’s soccer team.
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Key Holdings
•
The Eighth Circuit Court of Appeals affirmed the district court's dismissal, holding that K.T. failed to state a plausible Title IX claim because she did not adequately plead deliberate indifference, actual knowledge, or pervasive discrimination.
Citations
K.T. v. Culver-Stockton College, 865 F.3d 1054 (2017)
Legal Reasoning
The Eighth Circuit Court of Appeals reasoned that K.T. failed to adequately plead the elements of a Title IX student-on-student harassment claim. Specifically, the court found that K.T. did not plausibly allege that Culver-Stockton acted with deliberate indifference, had actual knowledge of discrimination, or that the alleged misconduct was sufficiently pervasive to deprive her of equal access to educational opportunities. The court emphasized that deliberate indifference must cause the harassment, actual knowledge requires prior notice of a substantial risk of peer harassment, and pervasive discrimination must be more widespread than a single instance of one-on-one peer harassment.
Outcome
The Eighth Circuit Court of Appeals affirmed the district court's order granting Culver-Stockton's motion to dismiss for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6).
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