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Anoka-Hennepin School District Complaint

Anoka-Hennepin School District Complaint

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Published by davidbadash

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Published by: davidbadash on Feb 09, 2012
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Jane Doe; K.R., by his next friends andparents, Rebecca Rooker and Jim Rooker;D.F., by his next friends and parents,Burnetta Frei and Jeffrey Frei; B.G., byher next friend and parent, Marty Geldert;and D.M.-B., by his next friends andparents, Michael McGee and JasonBackes;Plaintiffs,vs.Anoka-Hennepin School District No. 11;Anoka-Hennepin School Board; DennisCarlson, Michael Farley, Jerri McGonigal,and Tom Hagerty, in their officialcapacities,Defendants.
Civil No. _______________COMPLAINTJURY DEMAND
COME NOW Plaintiffs Jane Doe; K.R., by his next friends and parents, RebeccaRooker and Jim Rooker; D.F., by his next friends and parents, Burnetta Frei and JeffreyFrei; B.G., by her next friend and parent, Marty Geldert; and D.M.-B., by his next friendsand parents, Michael McGee and Jason Backes, (collectively “Plaintiffs”) and state thefollowing as and for their Complaint against Defendants Anoka-Hennepin School DistrictNo. 11 (the “School District”or “District”), Anoka-Hennepin School Board, DennisCarlson, Michael Farley, Jerri McGonigal, and Tom Hagerty (collectively “Defendants”).
1.This is a civil rights case brought by five current and former students of Defendant Anoka-Hennepin School District No. 11 in Minnesota. Plaintiffs seek tovindicate their constitutional and statutory rights to equal access to educationalopportunities, rights that Defendants have violated and will continue to violate absentrelief from this Court. Defendants’violation of these rights include the intentionalenactment and enforcement of policies that unlawfully discriminate against Plaintiffsbased on their actual or perceived sexual orientation. These policies exist only becauseof community animus toward lesbian, gay, bisexual, and transgender (“LGBT”) people –an interest that can never justify discrimination by the government.2.Plaintiffs have each suffered severe and pervasive gender-based harassmentand/or harassment on the basis of their actual or perceived sexual orientation at school, insome cases for years on end. Plaintiffs were subjected to slurs from other studentsbecause of Plaintiffs’perceived sexual orientation or gender expression, including“dyke,”“homo,”“fag,”“faggot,”and “queer,”nearly every school day. The verbal harassment of Plaintiffs and other students who are or perceived to be LGBT alsoincluded being called a “sinner”; being told, “you’re going to hell”; being told, “you’re aguy –act like a guy”; being told to “get out of our school, fag”; and being told to “killyourself”for being gay.
3.The harassment suffered by Plaintiffs was not limited to verbal insults.Other students also physically threatened, and in some cases, attacked Plaintiffs becauseof their sexual orientation or failure to conform to sex stereotypes. These attacksincluded being urinated on, being stabbed in the neck with a pencil, being choked, beingpushed into walls, being shoved forcefully into lockers, having objects thrown at them inclass, and having books knocked out of their hands,—acts often accompanied by anti-gayand gender-related slurs.4.These acts occurred on school grounds and some occurred in plain view of school officials. Plaintiffs and their parents also regularly reported the harassment toschool staff and administrators.5.Far from being isolated incidents, this type of verbal and physical abusewas a relentless and inescapable aspect of Plaintiffs’school experience. The harassmentcaused Plaintiffs’grades to drop and led each of the Plaintiffs to stay home from schoolat times to avoid the constant harassment. As a result of the harassment, several Plaintiffshave transferred to schools outside of the District and away from their friends andcommunities or withdrawn from school altogether. Being ostracized, humiliated,threatened, and attacked as a daily routine at school also caused Plaintiffs to sufferserious emotional harm, including anxiety, anger, and depression, which led some of them to consider or attempt suicide. Within a nine month period, between November2009 and July 2010, at least four LGBT students within the District did take their ownlives.

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