This time the defendant school district and its employees allowed the
plaintiffs’ White classmates to call them niggers
on numerous occasions over afour-year period.
The plaintiffs’ mother reached out to the high school principal
to report the conduct and ask for help several times, but he literally laughed inher face. The d
efendants’ deliberate indifference to the
was not only immoral, but as the Tenth Circuit made plain, it was illegal:It does not take an educational psychologist to
conclude that being referred to by one’s peers by the
most noxious racial epithet in the contemporary American lexicon, being shamed and humiliated on
the basis of one’s race, and having school authoritiesignore or reject one’s complaints would adversely affecta Black child’s ability to obtain the same benefit from
schooling as her white counterparts.
Bryant v. Indep. Sch. Dist. No. I-38 of Garvin Cnty, Okla
., 334 F.3d 928, 932(10th Cir. 2003).
Plaintiff A.A.A. is an adult Black female who at all relevant times was astudent at Zumbrota-Mazeppa High School.2.
Plaintiffs JANE DOE #1 and JANE DOE #2 (the “DOES”) are Black,
female minors who at all relevant times were students within theZumbrota-Mazeppa school district. The DOES are sisters. A.A.A. is the
DOES’ older sister.
L.L.A. is the mother of the individual plaintiffs. She is JANE DOE #1’s
and JANE DO
E #2’s legal guardian.
CASE 0:12-cv-01835-MJD-TNL Document 1 Filed 07/27/12 Page 2 of 15