1

8 KING COUNTY SUPERIOR COURT FOR THE STATE OF WASHINGTON

C.S.A., a minor, by and through his guardians NO.
9
B.W.A. and P.E.S.,
10 Plaintiff, COMPLAINT FOR VIOLATION OF THE
vs. WASHINGTON LAW AGAINST
11 DISCRIMINATION, VIOLATION OF THE
BELLEVUE SCHOOL DISTRICT NO. 405, PUBLIC RECORDS ACT, AND FAILURE TO
12 Defendant. PROTECT A MINOR STUDENT
13

14
I. INTRODUCTION
15
1. False allegations hurt.
16
2. Even more so, false allegations about dating violence cause significant harm.
17
3. But nothing can compare to the irreparable destruction of a student when false
18

19 allegations about dating violence are perpetuated by a school district with full knowledge that

20 the allegations were disproven by four independent investigations.

21 And that is what happened here.

22
4. At Newport High School in the Bellevue School District, a girl hit her ex-
23
boyfriend and vandalized his car. When the boy reported that criminal conduct to the school
24
and the girl was called in to give a statement, to avoid being suspended she made a false
25

26

COMPLAINT - 1
 allegation against him. The ruse worked: No discipline was imposed on the girl and instead,
1
four independent investigations commenced against the boy. They were conducted by:
2

3 a. Bellevue School District Office of Civil Rights and HIB Compliance;

4 b. Title IX Investigator Celeste Monroe of the law firm KARR TUTTLE CAMPBELL;

5 c. Bellevue Police Department; and

6 d. King County Prosecutor’s Office.
7
5. These comprehensive investigations showed not only that the boy was innocent,
8
but that the girl was the perpetrator of violence and false allegations. Yet even with these
9
independent investigations, the District took no action. Indeed, the District actually allowed
10
the girl to instigate a year-long hate campaign against her ex-boyfriend through false allegations
11

12 made on social media, on posters placed throughout the school, in the school newsletter, and

13 during rants on school grounds.

14 6. The District refused to publish the findings of the investigations so that the
15
student body could know the boy was innocent and the girl was the perpetrator. Instead, even
16
though the girl’s fabrications were disproven, the District let those lies mushroom into a false
17
and destructive narrative that permanently defamed the boy and made him the target of nonstop
18
bullying. By refusing to tell the truth about what happened and allowing the ongoing abuse of
19

20 this innocent youth, the District institutionalized a brutal harassment campaign against him.

21 7. This student and his family trusted the District. But they were betrayed when

22 the District allowed perpetrators to engage in an unchecked, year-long campaign of chaos,

23
threats, and harassment against this innocent young student.
24
8. The District must be held accountable so this never happens again.
25

26

COMPLAINT - 2
 II. NATURE OF THE CASE
1
9. This is an action for declaratory judgment, injunctive relief, violation of the
2

3 Washington Law Against Discrimination, and violation of the Public Records Act.

4 10. In addition, upon expiration of 60 days after the service of the Notice of Claim,

5 claims for compensatory damages for bullying, harassment, intimidation, retaliation, failure to
6 protect, and negligence will ripen under Washington law.1
7
11. Plaintiff, by and through his attorney Yvonne Kinoshita Ward, alleges the
8
following against Defendant Bellevue School District No. 405 (hereinafter “Defendant,” “the
9
District,” or “Defendant District”):
10
III. PARTIES, JURISDICTION & VENUE
11

12 12. The actions that are subject herein occurred in King County, Washington.

13 13. At all times material hereto, Defendant District operated in King County,
14 Washington.
15
14. At all times material hereto, Defendant District is a public school district
16
organized and operating under the laws of the State of Washington.
17
15. At all material times hereto, Defendant District is a government entity subject to
18
the Washington Constitution; Title 28A of the Revised Code of Washington; RCW 7.24 et seq.;
19

20 and Title 49.60 of the Revised Code of Washington.

21 16. Plaintiff C.S.A. is a minor. He is proceeding in this cause through his guardians

22 B.W.A. and P.E.S.

23

24

25
1 A motion to amend will be filed at that time.
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COMPLAINT - 3
 17. At all material times hereto, Plaintiff was a student enrolled within Defendant
1
District in King County, Washington.
2

3 18. At all material times hereto, there existed a special relationship between Plaintiff

4 and Defendant and Defendant’s employees, representatives, volunteers, staff, and agents.

5 Defendant District owed Plaintiff affirmative duties, including taking sufficient remedial action
6 to protect him from harm; providing a safe educational environment; and refraining from
7
retaliation and/or other misconduct against him.
8
19. Defendant District is responsible for all conduct, acts, errors, and omissions of its
9
board members, superintendents, administrators, principals, teachers, counselors, volunteers,
10
employees, and other agents complained of herein.
11

12 20. Pursuant to RCW 4.96.020, a Notice of Claim has been presented to the

13 Defendant District.
14 21. The Notice of Claim referenced in the preceding paragraph provided adequate
15
notice as to all tort claims alleged herein.
16
IV. ALLEGATIONS
17
22. In Fall 2021, Newport High student A.S. vandalized the car of C.S.A. because they
18
had broken up. She shoved and hit him in the school parking lot, swore at him, followed him,
19

20 and would not leave him alone. The District should have reported A.S.’s conduct to the police

21 and disciplined her. Instead, the District merely directed the two to stay away from each other

22 by signing a no-contact agreement.

23
23. C.S.A. immediately signed, hoping this would keep A.S. away from him. But A.S.
24
could not let go and refused to sign. Yet the District took no protective action even though A.S.
25

26

COMPLAINT - 4
 admitted to assaulting C.S.A., admitted to vandalizing his car, and brazenly defied the no-
1
contact directive.
2

3 24. Frustrated that C.S.A. was ignoring her and seeing that the District would not

4 intervene, A.S. formed a group to start a hate campaign against him. This led to four

5 independent investigations into A.S.’s accusations conducted by the Office of Civil Rights; a
6 Title IX investigator; the Bellevue Police Department; and the King County Prosecutor’s Office.
7
25. The investigations found that C.S.A. engaged in no misconduct whatsoever. In
8
fact and to the contrary, the investigations disclosed that A.S. assaulted, harassed, and stalked
9
C.S.A. The investigations further established that A.S.’s egregious misconduct towards C.S.A.
10
disrupted his education, inflicted emotional distress, and caused other students to ostracize
11

12 him.

13 26. Despite these four investigations, the District took no steps to educate the
14 student body about the investigative findings and clear C.S.A.’s name. Its refusal to do so
15
allowed A.S.’s false and defamatory campaign to not only continue, but also permeate the entire
16
school environment. Indeed, the District itself reinforced the hate campaign through classroom
17
instruction, the school newsletter, videos, school advisors, and refusal to investigate and/or
18
discipline the well-documented harassment A.S.’s group inflicted upon C.S.A.
19

20 A. A.S.’S HISTORY OF FALSE ALLEGATIONS INCLUDES SETTING UP A MALE AS A

PEDOPHILE
21
(a) The Setup
22
28. Before A.S. went after C.S.A., she tried to have a black male falsely arrested as a
23
pedophile.
24

25

26

COMPLAINT - 5
 29. According to Bellevue Police Department records, A.S. and a male engaged in
1
graphic sexting. He asked for provocative pictures and A.S. obliged, even stating “that’s pretty
2

3 hot” about herself. [Picture inappropriate for public filing].

4 30. Once the male responded, A.S. told him she was a minor and taunted that she was

5 going to have him thrown in jail:

6

10

11 31. Shocked, the male immediately responded that A.S. had lied about her age. She

12 mockingly responded “lmaoo:”

13

14

15

16

17 32. The male called her out on the setup and racism, and A.S. just laughed at him:
18

19

20

21

22

23

24

25 33. The male disengaged and signed off:

26

COMPLAINT - 6
1

4 Bellevue Police Department Records, pp. 11-13.

5 (b) The False Report To The Police

6 34. After the male disengaged, A.S. reported him to the police as a pedophile. The
7
case was forwarded to the detective unit for a full investigation. After investigating the facts,
8
detectives found no evidence that the male did anything illegal:
9

10

11

12

13
Bellevue Police Department Records, October 2021.
14
35. Therefore as a false report, the police closed the case.
15
B. ROUND TWO: TAKING DOWN A YOUNGER STUDENT
16

17 36. A.S. set sights on a student younger and more trusting: Plaintiff C.S.A.

18 (a) A.S. Stalks C.S.A.

19 37. A.S. and C.S.A. dated sporadically in late summer 2021. A.S. became infuriated
20 when C.S.A. distanced himself from her and they broke it off.
21
38. But A.S. would not let go. Looking for excuses to be near C.S.A., she told him she
22
left earrings in his car. C.S.A. let her search his car in the school parking lot, but he left when it
23
became obvious there were no earrings and it was just another ruse. A.S. angrily followed
24
C.S.A., pushing and hitting him and demanding that he stop walking away from her. A video of
25

26

COMPLAINT - 7
 the event was transcribed during the Title IX Investigation, documenting A.S.’s stalking and
1
assaultive behavior:
2

10

11

12

13

14

15 Title IX Investigative Report, p. 4. The investigator noted the tenor:

16

17

18
Title IX Investigative Report, p. 4.
19
(b) Hell Hath No Fury Like a Woman Scorned
20
39. Having escaped A.S., C.S.A. made it to class and finished out the school day. But
21

22 when he returned to his car, he found it smeared over with ketchup that had caked on and was

23 difficult to remove. Realizing that A.S. would not leave him alone, C.S.A. immediately filed a
24 harassment, intimidation, and bullying (“HIB”) complaint:
25

26

COMPLAINT - 8
1

6
Harassment Intimidation Bullying Report, September 24, 2021.
7

8 40. The assistant principal set an interview with A.S. to investigate. Before it

9 commenced, A.S. confessed to her English teacher what she had done and that she was afraid of

10 getting suspended:
11

12

13

14 Title IX Investigative Report, p. 5.

15 41. So by the time A.S. was called into the office, she had a new story worked out to
16
avoid suspension. For the first time ever, A.S. claimed that C.S.A. once hit her arm and pushed
17
her. But when asked, A.S. could not recall a single date, time, or place for this supposed event.
18
Even so her tactic worked: rather than discipline A.S. for vandalism and assault, the District
19
backed down and just told each student to stay away from the other by signing a “mutual” safety
20

21
plan.

22 42. Even though he had done nothing wrong, C.S.A. was encouraged by a plan -- any

23 plan -- that would keep A.S. away from him. Both he and the assistant principal immediately
24 signed the agreement. But the thought of no contact angered A.S. and she refused to sign:
25

26

COMPLAINT - 9
1

10

11

12
C.S.A. & Assistant A.S. refused
13
Principal signed to sign
14
HIB Safety Plan, September 24, 2021.
15

16 43. Even though A.S. refused to stay away from C.S.A. after admitting to assault and

17 vandalism against him, the District took no protective action. It did not report A.S.’s admitted
18 criminal conduct to the police. Rather, the District reported to police her accusations against
19
C.S.A., raised only after she was called into the office and worried about getting suspended.
20
(c) A.S. Did Not Want the Police Involved Because She Knew Her Lies
21 Would be Exposed
22 44. When the assistant principal offered to report her accusations against C.S.A. to
23
the police, A.S. immediately got upset and asked him not to make that report:
24

25

26

COMPLAINT - 10
1

3
Title IX Investigative Report, p. 21.
4
(d) A.S. admits C.S.A. was not inappropriate
5
45. It did not take long for A.S.’s story to unravel. She admitted her misconduct and
6

7 also that C.S.A. did nothing wrong:

10

11

12 Title IX Investigative Report, p. 6.

13 46. In addition, for several years A.S. routinely confided personal information to her
14
school counselor:
15

16

17

18

19 Title IX Investigative Report, p. 9.

20 47. Yet in the face of this four-year personal relationship, at no time did A.S. report
21 any improper behavior by C.S.A. In fact, her only “complaint” was that he was not as invested in
22
the relationship as she was:
23

24

25

26

COMPLAINT - 11
 Title IX Investigative Report, p. 9.
1

2
(e) A.S. Tries to Blackmail C.S.A. for Jewelry and Cash

3 48. The assistant principal offered to file a police report against C.S.A. Seeking to

4 avoid a police investigation that would uncover her scheme, she instead said that she would

5 drop everything if C.S.A. gave her cash and jewelry:

6

8
Title IX Investigative Report, P. 7.
9
49. C.S.A. refused to be blackmailed by A.S. He did not give her cash and he did not
10

11 give her jewelry. Instead, he focused on avoiding any contact with her.

12 (f) A.S. continues to obsess about C.S.A.

13 50. C.S.A. made extraordinary efforts to keep A.S. out of his life but she would not
14
leave him alone. According to the Civil Rights Investigation, she kept trying to get close to him:
15

16

17

18 Civil Rights Investigative Report, p. 4.

19 (g) A.S. Announces She Will Make “Chaos” For C.S.A. The District
Cowardly Stands Down
20
51. Unfortunately C.S.A. was trapped. The more he ignored A.S., the more aggressive
21

22 she became. After repeated requests from C.S.A.’s family, the principal finally met with A.S. and

23 asked (but did not tell) her to stop. The principal reported that A.S. openly defied her and said

24 she intended “to make chaos” for C.S.A. And with no deterrence from the District, A.S. publicly
25
confirmed that intent and to “feed the fire:”
26

COMPLAINT - 12
1

8
Exhibit 11 to Title IX Investigative Report.
9
52. Despite A.S.’s pronouncement she was going to “create chaos” and “feed the fire”
10
against C.S.A., the District did absolutely nothing.
11

12 53. And so it began. With the District backing down, A.S. formed a group to

13 perpetuate her campaign of “chaos” against C.S.A. The group attacked him through social media

14 vitriol, libelous posters, shoving, pushing, verbal abuse, threats, false articles in the school
15 newsletter, and trying to get him kicked out of the Robotics Club.
16
54. Group member B.G. started things off by stalking C.S.A. in the halls, constantly
17
screaming “fuck you you’re an asshole I hate you!” Next, the group made false allegations on
18
social media and even posted defamatory signs in bathrooms:
19

20

21

22

23

24

25 Civil Rights Investigative Report, Exhibit 6.

26

COMPLAINT - 13
 55. The Civil Rights Investigation found that as a result of the campaign of chaos,
1
other students piled on:
2

7
Civil Rights Investigative Report, p. 4.
8
56. Yet even with these determinative findings of the Civil Rights Investigation, the
9

10 District took no steps to intervene. And when the harassers saw the District was backing down,

11 they became increasingly emboldened and escalated their hate campaign.

12 (h) The Group Tried to Get C.S.A. Kicked Out of the Robotics Club
13 57. Even with the social media vitriol, libelous posters, verbal attacks, and other
14
bullying, C.S.A. continued to ignore A.S. Unable to get to him that way, the group set a secret
15
Robotics Club meeting to kick him out. This was a targeted attack because the Robotics Club
16
was important to C.S.A.; in fact, he served as the club’s business lead and treasurer.
17

18
58. The Title IX Investigation found that the secret meeting was called to punish

19 C.S.A. and kick him out:

20

21

22

23

24 Title IX Investigative Report, p. 13.

25

26

COMPLAINT - 14
 59. The only reason this was stopped was because one of A.S.’s friends prematurely
1
posted online what they were going to do. A complaint was immediately filed and the post
2

3 taken down, but the District did not discipline a single student for this misconduct. In fact, no

4 steps were taken even though the District acknowledged that Robotics had become unsafe for

5 C.S.A.:
6

10

11

12

13

14

15

16

17
November 5, 2021 Pham Email.
18
60. Yet despite acknowledging safety was at issue, yet again the District took no
19
protective action. In fact, the exact opposite occurred when a Robotics Club advisor was
20
allowed to pile on C.S.A. by forcing the club to watch a presentation she concocted about
21

22 “dating violence.”

23 (i) The Robotics Advisor Targets C.S.A.

24 61. Now, there is nothing in the Robotics Club Constitution or by-laws that directs
25 it to discuss anything but, well, Robotics. Yet this advisor took it upon herself to humiliate
26

COMPLAINT - 15
 C.S.A. by forcing her “dating violence” slide show onto the club at a mandatory meeting. She
1
strategically timed the infliction of her personal “dating violence” slides to occur immediately
2

3 after the attempt to get C.S.A. kicked out of Robotics failed and in the midst of the hate

4 campaign against him.

5 62. Unfortunately the advisor was successful. As she talked about “dating violence,”
6 club members stared and laughed at C.S.A., shaming, embarrassing, and ostracizing him even
7
further. This was especially crushing because the Robotics Club had always been a safe space
8
for C.S.A. It was a place where kids could get together and focus on their mutual interest in
9
Robotics without the noise and drama of the outside world.
10
63. Despite this highly inappropriate conduct, to date that advisor has not been
11

12 removed or even admonished for abusing her position to target C.S.A. in such a harmful way.

13 (j) The District Allowed the Group to Publicly and Falsely Accuse C.S.A.
and Other Students
14
64. On November 19, 2021, the group incited students to riot. Using a megaphone,
15

16 the group falsely accused C.S.A. of the debunked accusations and publicly called him a “piece of

17 shit:”

18

19

20

21

22

23

24

25

26

COMPLAINT - 16
 65. The prevaricators also engaged in racism and sexual harassment by denigrating
1
other students’ race and gender. Yet at no time did the District intervene and stop the
2

3 misconduct or explain the accusations had been proven false. Instead, the District allowed this

4 group of harassers to continue with their vitriol and then bask in the attention:

10

11

12

13
66. The District stood by as these harassers publicized degrading remarks against
14
fellow students, during school hours and on school grounds. The besieged students were
15
defamed, humiliated, and targeted in the worst possible way given their young ages.
16
(k) The District did not intervene until the harassers swore at school
17
officials.
18
67. Not a single harasser was investigated or disciplined for their abusive behavior
19
towards students. However, the moment they directed swearwords towards school officials,
20
the District sprang into action. The harassers had turned their venom to administrators, calling
21
the assistant principal “bitch” and leading profane chants:
22

23

24

25

26

COMPLAINT - 17
 Report of Assistant Principal Keith Altenhoff, P. 1.
1

2
68. A.S. then ratcheted up the vitriol:

6 Report of Assistant Principal Keith Altenhoff, p. 1.

7 69. Thus the group -- self-appointed justice warriors purportedly against sexual
8
harassment -- had no problem attacking students and administrators in sexualized terms:
9

10

11

12
Report of Assistant Principal Keith Altenhoff, p. 2.2
13

14 70. Although the District comfortably stood by as minor students were vilified and

15 defamed through bullhorns on school grounds, the District responded immediately when the

16 harassers flipped the script and swore at school officials. Only after administrators were
17
targeted did the District call law enforcement to end the riot. The District then moved quickly
18
to discipline the harassers only for what they said about administrators. At no time did the
19
District investigate, let alone take action against, the harassers for what they did to C.S.A. and
20
other students at the riot.
21

22
(l) The District Allowed the False Narrative to Fester, Grow, and
Explode
23

24

25
2 "Dion" refers to School Principal Dion Yahoudy. Since she is not a student, her name is not redacted.
26

COMPLAINT - 18
 71. When it became apparent that the District would take no steps to protect C.S.A.
1
and other students targeted by the group, they cranked it up a notch.
2

5 72. Group member K.C. ran a student flyer called “Knightlife” and they used that
6
medium to continue the false narrative against C.S.A. On December 10, 2021, they published an
7
inaccurate and false story about the November 19 riot, posturing disproven claims as true with
8
no independent investigation. The group refused to report on the aggression, vitriol,
9
defamation, and violence that took place.
10

11 73. To further the false narrative, the group personally handed out the flyer to

12 students during lunch to ensure maximum exposure:

13

14

15

16

17

18

19

20

21

22

23

24 Newport High School Lobby, December 10, 2021.

25

26

COMPLAINT - 19
 74. A complaint was immediately filed with the District. Because it was
1
perpetuating the false narrative, C.S.A.’s family asked that the truth be shared with the student
2

3 body. The District refused. The family asked that the detailed civil rights investigative findings

4 be distributed so students and their families could see the facts. The District refused. The

5 family urgently asked what would be done to counter the false and disproven accusations. The
6 District ignored their pleas.
7
C. THE DISTRICT’S FAILURE TO TAKE PROTECTIVE STEPS AND PROVIDE FACTS
8 TO THE STUDENT BODY RESULTED IN WIDESPREAD AND PERVASIVE
HARASSMENT AGAINST C.S.A.
9
75. The ”Knightlife” story, on the heels of the public attacks against C.S.A., greenlit
10
him for even more bullying and harassment.
11

12 (a) “Kill Yourself”

13 76. C.S.A. had avoided social media because of the increasingly pervasive hate

14 campaign. As the holiday break approached he was hoping everything died down so he checked
15 his account. There he found a message stating “kill yourself:”
16

17

18

19

20

21

22

23

24 77. This was immediately reported to the administration and it was able to track the
25
post to a person who graduated from Newport High School the prior June. However, even
26

COMPLAINT - 20
 though that person was no longer a student and not protected by confidentiality, the District
1
refused to disclose the perpetrator or report it to the police. The District knew who he was yet
2

3 refused to give C.S.A. critical information he needed to protect himself.

4 (b) No Fresh Start After the Holidays

5 78. C.S.A. was hoping for a fresh start after Christmas break. There had been
6 comprehensive, independent investigations showing that A.S. made up the allegations and that
7
C.S.A. was unfairly persecuted for it. With the lies, social media posts, bathroom posters, public
8
excoriation, and “Knightlife” flyer behind him, C.S.A. looked forward to starting school anew.
9
79. But A.S. would not allow that. Her obsession with C.S.A. escalated as he
10
continued to ignore her. As the new quarter began, A.S. demanded no one associate with him:
11

12

13

14

15

16
A.S. January 4, 2022 Post.
17

18 80. This was immediately reported to the District. But again it took no action,

19 greenlighting harassers to reignite their campaign of chaos to kick off the new quarter.
20 81. Immediately B.G., the girl who hounded C.S.A. in the fall without repercussion,
21
began physically and verbally harassing him again. At first the District declined to investigate;
22
only at the insistence of C.S.A.’s lawyer did it reverse course and look into the misconduct.
23
Because of witnesses, the District had no choice but to find harassment occurred:
24

25

26

COMPLAINT - 21
 Harassment Intimidation & Bullying Report & Finding, February 7, 2022.
1

2
82. Yet even with her repeated offenses, no repercussion was imposed. B.G. was not

3 suspended but merely told to “minimize any contact opportunity” with C.S.A.

4 (c) C.S.A. is Again Threatened With Violence

5 83. C.S.A. put up with pushing and shoving by other students throughout fall
6
quarter. When that resumed in January, the family again asked the District to publish the
7
investigation findings so the student body could have the facts. The District declined. In fact, it
8
refused to take protective actions even though its own investigations found that C.S.A. broke no
9
rules, complied with all District directives, and was suffering immensely in that the truth was
10

11
being withheld by the District:

12

13

14
Civil Rights Investigative Report, p. 6.
15
84. With the District greenlighting open season on C.S.A., the campaign of chaos
16
escalated into threats of violence. Student O.P., who previously harassed C.S.A. throughout the
17

18 fall with no repercussions, accosted C.S.A. in the school parking lot. O.P. shouted “woman

19 beater!” And screamed “I am going to beat the sh** out of you!”

20 85. Due to eyewitnesses and video evidence, the District could not get out of making
21
a harassment finding. But even in the face of threatened assault, the District did not make a
22
referral to law enforcement. It took no action against the student except to tell him to stay away
23
from C.S.A. And rather than force the perpetrator to change his behavior, the District instead
24
made C.S.A. park somewhere else.
25

26

COMPLAINT - 22
 86. The open season against C.S.A. continues to this day. Recently three seniors
1
brazenly harassed C.S.A. right front of administrators at the front office. The family made a
2

3 report and urged the District to immediately interview administrators who were present. Again

4 because of witnesses, the District was forced to find harassment and bullying had occurred. But

5 yet again, the only “consequence” was just telling these bullies to stay away from C.S.A.
6 D. THE INVESTIGATIONS CONSISTENTLY FIND THAT A.S. IS THE PERPETRATOR
7
OF SERIOUS MISCONDUCT AGAINST C.S.A.

8 87. Multiple investigations established that A.S. made up allegations against C.S.A.

9 because she was in trouble for vandalizing his car and hitting him. She nevertheless refused to

10 comply with the no contact directive:

11

12

13

14

15

16 Civil Rights Investigative Report, p. 7.

17 88. Despite this determination by the Office of Civil Rights, the District declined to
18
take corrective action. Therefore with no repercussions imposed, the green light stayed on and
19
the campaign of chaos ramped up even further:
20

21

22

23

24
Civil Rights Investigative Report, p. 7.
25

26

COMPLAINT - 23
 89. The Civil Rights Investigation noted that C.S.A. “has complied with the
1
directives in the safety plan.” Likewise the Title IX Investigation found:
2

5
Title IX Investigative Report, p. 23. In addition, independent investigations by law enforcement and
6
the prosecutor’s office found no evidence to support A.S.’s claims.
7
E. THE DEVASTATING IMPACT OF THE DISTRICT’S INACTION
8
90. C.S.A. did everything the District asked. For each incident of harassment and
9

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bullying, he promptly reported to the administration. He pulled himself off of all social media.

11 He complied with all directives of the District. And at the District’s instruction, he did not post

12 about or discuss the facts of what really happened. At the District’s direction, he stayed quiet.
13 He did so while A.S.’s group ran amok with its defamatory hate campaign.
14
91. Despite the clear record confirmed by four independent investigations that A.S.’s
15
claims were false and C.S.A. engaged in no misconduct whatsoever, the District has refused to
16
ensure the student body knows the truth about who the real danger is. This has resulted in a
17
profound and permanent impact upon C.S.A., a kid just trying to enjoy Robotics and excel
18

19 academically:

20

21

22

23 Civil Rights Investigative Report, p. 7. As C.S.A. stated:

24

25

26 Civil Rights Investigative Report, p. 6.

COMPLAINT - 24
 F. THE DISTRICT FORCED THE FAMILY TO TAKE LEGAL ACTION.
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92. C.S.A. will be quiet no longer.
2
93. The District knew that multiple independent investigations proved not only that
3

4 C.S.A. was innocent, but that A.S. was the perpetrator of criminal conduct against him. District

5 officials knew that A.S. would defy the safety plan and that she was orchestrating a “campaign of

6 chaos” against C.S.A.; they knew because she repeatedly told them and she broadcast it on social
7
media. Yet rather than shut down the campaign of chaos, the District backed down and
8
instructed C.S.A. to remain silent. It took no action to stop the harassment, tell the truth, and
9
correct the destructive narrative permeating the school.
10
94. The District did everything it could to avoid its legal duty to provide a safe
11

12 learning environment. When problems first arose, rather than investigate the harassment the

13 District instead told the family it would be easier if C.S.A. just transferred to another school.

14 When the family declined and insisted on investigations, the District did so only after C.S.A.’s
15
family hired a lawyer. It then slow-walked the requests, proceeded under the wrong legal
16
standards, and imposed no consequences on perpetrators.
17
95. In resisting the work necessary to provide a safe learning environment, the
18
District illegally obstructed access to records necessary to address C.S.A.’s safety. The District
19

20
then withheld agreed safety plans from teachers and relevant staff – – a critical step to allow

21 frontline school employees to ensure student safety. And when the failure to distribute the

22 safety plan was uncovered and objection was made, the District retaliated by illegally
23 distributing C.S.A.’s confidential health and education information.
24
96. C.S.A. will stay silent no longer. Even though the District is legally obligated to
25
put school safety first, it has repeatedly shown it either cannot or will not do so. The only way
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COMPLAINT - 25
 to get the District to provide a safe learning environment is to shine a light on its misconduct
1
and have the justice system make the District do its job.
2

3 V. RECORDS

4 97. To formulate an effective safety plan, Plaintiff sought records from Defendant

5 District. In violation of law the District purposefully withheld responsive records, including but
6 not limited to documents pertaining to:
7
a) Harassment, intimidation, and bullying perpetrated against Plaintiff;
8
b) “Town Hall,” PTSA, and other meetings perpetrating false narratives and wrong
9 standards regarding allegations of “dating violence;”

10 c) Videos of the harassment and other misconduct directed against Plaintiff;

11 d) The “riot” on November 19, 2021;
12 e) Actions of Robotics Club members regarding Plaintiff;
13
f) Actions of students involved with the “Knightlife” flyer issued December 10, 2021;
14
g) Harassment in History class;
15
h) Harassment in English class;
16
i) Safety plans that were altered and/or not distributed;
17
j) The “kill yourself” social media post;
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k) The March 20, 2022 harassment incident; and
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l) The April 25, 2022 harassment incident.
20
VI. CLAIMS
21

22 98. Defendant District failed to abide the law and its own policies to address prolific,

23 abusive, and rampant misconduct against Plaintiff. Defendant District failed to adequately

24 maintain and enforce disciplinary policies and procedures, including those related to
25
harassment, intimidation, bullying, assaults, retaliation, and other misconduct.
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COMPLAINT - 26
 99. Defendant District’ conduct violated the Washington Law Against
1
Discrimination by treating male and female students disparately in their legal duties to address
2

3 and prevent bullying, intimidation, and harassment; in their application of conduct rules; in

4 their enforcement of conduct rules; in their imposition of sanctions for alleged violation of

5 conduct rules; in their duty to protect students in their care; and by application of disparate
6 standards regarding conduct based upon gender.
7
100. Defendant District had knowledge of harassment, intimidation, bullying,
8
assaults, retaliation, and other misconduct against Plaintiff that endangered students in their
9
care and failed to act reasonably to stop it.
10
101. Defendant District illegally withheld records to which Plaintiff and his parents
11

12 had a right to access under RCW 28A.605 et seq.

13 102. Defendant District illegally withheld records to which Plaintiff and his parents
14 had a right to access under RCW 42.56 et seq.
15
103. Defendant District’s deliberate indifference to harassment, intimidation, bullying,
16
assaults, retaliation, and other misconduct created an unsafe environment and unreasonably
17
interfered with Plaintiff’s ability to obtain an education.
18
104. Defendant District ratified the acts of its agents and employees in their conduct
19

20 towards Plaintiff.

21 VII. PRAYER FOR RELIEF

22 Plaintiff requests that this court award relief, including judgment that:
23
a) Defendant District violated statutes, regulations, and its own policies in
24
its actions pertaining to Plaintiff;
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26

COMPLAINT - 27
 b) Directs Defendant District to implement and enforce a safety plan
1
approved by an agreed education expert or this court;
2

3 c) Orders immediate production of requested records;

4 d) Awards Plaintiff all costs, including reasonable attorney fees, incurred in

5 connection with this action; and

6 e) Grants other relief deemed appropriate by this Court.
7
RESPECTFULLY SUBMITTED on June 14, 2022.
8
YVONNE KINOSHITA WARD LLC
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10

11 Yvonne Kinoshita Ward, WSBA #20276

Attorney for Plaintiff
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COMPLAINT - 28