Shawn Prather v. East Baton Rouge Parish School Board and Richard Day

Summary

The ruling addresses motions for summary judgment in a civil action arising from the alleged sexual abuse of a student by a teacher in 1985. The court grants Principal Richard Day’s motion, grants the School Board’s motion as to the federal claims, and denies it as to the state-law claims. The opinion discusses qualified immunity, supervisory liability under 42 U.S.C. § 1983, deliberate indifference, and the admissibility of newspaper articles at summary judgment.

Holdings

1. Day was entitled to qualified immunity because, even viewing disputed facts and inferences in Prather's favor, the evidence did not establish deliberate indifference to an obvious risk of sexual abuse under controlling Fifth Circuit precedent.
2. The School Board was entitled to summary judgment on Prather's § 1983 claims because Prather failed to present competent summary-judgment evidence of an official policy, widespread practice, pattern, or custom that was the moving force behind the constitutional violations.
3. Summary judgment was denied on the School Board's Louisiana-law negligent-supervision claim because a reasonable jury could find that the School Board knew or should have known of a risk posed by Davison and that heightened supervision could have prevented the harm.
4. Summary judgment was denied on the School Board's Louisiana-law negligent-training claim because a reasonable jury could find that Day was inadequately trained and that the lack of training caused Prather's injuries.
5. Summary judgment was denied on the School Board's Louisiana-law vicarious-liability claim because a reasonable jury could find that Davison acted within the course and scope of employment.

Questions Presented

1. Whether Richard Day was entitled to qualified immunity on Prather's § 1983 supervisory-liability claim based on alleged failure to investigate, train, or supervise Davison.
2. Whether the School Board could be held liable under § 1983 for an official policy, custom, failure to adopt a policy, failure to train, or failure to supervise that caused the constitutional violations.
3. Whether genuine disputes of material fact precluded summary judgment on the School Board's Louisiana-law negligent supervision and negligent training claims.
4. Whether the School Board could be vicariously liable under Louisiana law for Davison's intentional sexual assaults committed at school during school hours.

Disposition

other