Sandra T.E. v. Grindle

Dist. Ct. did not err in denying defendant-principal's motion for summary judgment asserting qualified immunity in section 1983 action alleging that defendant denied plaintiffs (students/victims of sexual abuse of band teacher) equal protection by failing to investigate plaintiffs' sexual abuse complaints. At time of alleged events, supervisor could be held liable for participating in or deliberately turning blind eye to equal protection violation committed by her subordinate, and plaintiffs presented sufficient evidence to allow jury to conclude that plaintiff was aware of band teacher's sexual abuse of plaintiffs and deliberately helped to cover it up by misleading plaintiffs' parents and other school administrators about nature of plaintiffs' complaints. Plaintiffs also stated viable substantive due process claim arising out of their contention that defendant's alleged indifference deprived them of their protected interest in bodily integrity.