Stoneking v. Bradford Area School District

Kathleen Stoneking (plaintiff) attended Bradford Area High School. Edward Wright, the school’s band director, sexually assaulted Stoneking on multiple occasions. Wright was later convicted of various sexual crimes. Stoneking sued Frederick Smith, the school’s principal, Richard Miller, the school’s vice principal, and Frederick Shuey, the district’s superintendent (defendants), individually under 42 U.S.C. § 1983. Stoneking’s complaint alleged that, prior to Wright’s assaults on Stoneking, another band student complained to Smith that Wright had assaulted her and that Smith’s only response was to assert a policy that Wright was not to be one-on-one with female band students. At trial, witnesses testified that Smith and Miller had, on three occasions, received complaints from female students that Richard DeMarte, a social studies teacher, had sexually assaulted them. The witnesses testified that Smith and Miller discouraged the students from pursuing further action, implying that a student’s word would not be taken over that of a teacher and also implying that one student sought to frame DeMarte. One former band student testified that when she reported to Smith and Miller that Wright had sexually assaulted her, Smith blamed her for the incident. The student further testified that Smith and Miller tried to force the student to recant her story in front of the band. Beyond the policy that Wright was not to be one-on-one with female band students, Smith and Miller took no disciplinary action against Wright or DeMarte. Smith, Miller, and Shuey moved for summary judgment on the grounds that they enjoyed qualified immunity. The district court denied the motion, and the court of appeals affirmed. Both courts relied on common law and statutory duties to justify their holdings. The men appealed to the United States Supreme Court, which ordered the court of appeals to reconsider in light of a newly issued Supreme Court opinion that narrowed the ability to base § 1983 claims on common law and statutory duties.