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In a Matter of First Impression, the Eleventh Circuit Found Deliberate Indifference is the Standard Applicable to a Title VI Claim

Adams v. Demopolis City Schools

By Anna Grace Phillips

The Court affirmed summary judgment on all claims in favor of a school system and its officials and, as a matter of first impression, addressed whether the deliberate indifference standard is applicable to a Title VI claim. Jasmine and Janice Adams, the mother and grandmother of an elementary school student who committed suicide, filed a 42 U.S.C. § 1983 action against Demopolis City Schools (“DCS”) and school officials on behalf of the child’s estate. The Adamses alleged that the school officials were deliberately indifferent to sex-based harassment and discrimination in violation of Title VI, Title IX, the Fourteenth Amendment, and state law.


The ruling highlights the standards required by Title VI, Title IX, the Fourteenth Amendment, and state law and establishes deliberate indifference as the standard applicable to all future Title VI claims. While the Eleventh Circuit expressed its deep sympathy for the tragic loss of McKenzie Adams, it concluded that the applicable standards were not met for each of the Adamses’s claims and held that the district court did not err in granting summary judgment on all claims in favor of DCS and its school officials.


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