Lawsuit 5s1o4l
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David M. Ring (SBN 151124) Sonya Ostovar (SBN 307207) TAYLOR & RING 1230 Rosecrans Avenue, Suite 360 Manhattan Beach, California 90266 Telephone: (310) 209-4100 Attorneys for Plaintiffs, JANE DOE, a minor, by and through her guardian, HEIDI B., HEIDI B., individually, and JACOB B., individually
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
FOR THE COUNTY OF PLACER
10 11 12 13
JANE DOE, a minor, by through her guardian, HEIDI B.; HEIDI B., individually; and JACOB B., individually
14
Plaintiffs,
15
-vs.-
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PLACER UNION HIGH SCHOOL DISTRICT, a public entity; BENJAMIN DUNCAN, individually; and DOES 1-60, Defendants.
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) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )
CASE NO. COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
Plaintiff, JANE DOE, a minor, by and through her guardian, HEIDI B., HEIDI B., individually, and JACOB B., individually hereby file their Complaint and complain and allege as follows:
25 26 27 28
/// /// THE PARTIES
1
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
1.
Plaintiff JANE DOE (“Plaintiff”) is currently a 16-year-old female who resides in El
2
Dorado County, California. Plaintiff was a victim of sexual harassment perpetrated by her teacher and
3
band director at Del Oro High School in Loomis, California. As such, Plaintiff's identity has been
4
concealed from public court filings in order to prevent those not directly involved in this action from
5
learning her identity and making her identity public. Such a public disclosure would further harm
6
Plaintiff.
7 8 9 10 11
2.
Plaintiff HEIDI B. is Plaintiff JANE DOE’s mother who currently resides in El Dorado
County, California. 3.
Plaintiff JACOB B. is Plaintiff JANE DOE’s father who currently resides in El Dorado
County, California. 4.
Defendant PLACER UNION HIGH SCHOOL DISTRICT (“PUHSD”) and DOES 1
12
through 10 is a public school district existing under the laws of the State of California. Its main office is
13
located at 13000 New Airport, Auburn, CA 95603.
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5.
Defendants DOES 11-30 are s, teachers, staff, employees and agents of
15
Defendant PUHSD who owed a duty of care to Plaintiff and breached that duty of care, as described in
16
more detail herein.
17
6.
Del Oro High School is a high school operated by and under the control of Defendant
18
PUHSD, its governing school board, superintendent, s, and employees. Del Oro High
19
School is located at 3301 Taylor Rd, Loomis, CA 95650.
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7.
Defendant BENJAMIN DUNCAN and DOES 31-40 was a resident of Placer County,
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California. DUNCAN’s misconduct toward Plaintiff, includes sexual harassment, interference with the
22
education of a minor, and other tortious misconduct during the 2015-2016 and 2016-2017 school year
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when Plaintiff was approximately 14-16 years old. At the time, DUNCAN was in his mid-30s.
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8.
Jurisdiction is proper in Placer County because the defendants are either residents of
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Placer County or do business in Placer County, and also because the acts which are the basis of this
26
lawsuit occurred in Placer County.
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9.
The true names and capacities of each defendant designated herein as DOES 1 through
60, whether an individual, business, public entity, or some other entity, are presently unknown to
2
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
Plaintiff, who therefore sues said defendants by such fictitious names, pursuant to Code of Civil
2
Procedure section 474. Each DOE defendant is responsible in some actionable manner for the events
3
alleged herein. Plaintiff will amend the Complaint to state the true names and capacities of said
4
defendants when the same have been ascertained.
5
10.
Each of the defendants sued herein as DOES 1 through 60 was the agent and employee of
6
each of the remaining defendants and was at all times acting within the course and scope of such agency
7
and employment with the full knowledge, consent, authority, ratification and/or permission of each of
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the remaining defendants.
9 10
11.
them, is intended to include, and shall be deemed to include, all fictitiously named defendants. GENERAL ALLEGATIONS
11 12 13 14
Wherever appearing in this complaint, each and every reference to Defendants, or any of
12.
Plaintiff was 14 years old when she entered the tenth grade for the 2015-2016 school year
at Del Oro High School. Defendant Benjamin Duncan was Plaintiff’s teacher and school band director. 13.
Soon after the school year began, Duncan began “grooming” Plaintiff with the calculated
15
intent to gain her trust and friendship beyond what would be considered a “normal” teacher-student
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relationship. Duncan’s intent for doing so was and remains unclear. But, his actions in doing so were far
17
beyond any normal boundaries between a teacher and student. Duncan began the grooming process
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through constant text messages, emails, and phone calls to Plaintiff at all hours of the day and night,
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generally starting around 5:00 a.m. in the morning and up until 2:00 a.m. at night. Duncan exchanged
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thousands of personal text messages with Plaintiff during the months he was grooming her. Duncan also
21
routinely made secret late-night phone calls to Plaintiff, which often lasted hours at a time. Duncan also
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often wrote personal handwritten notes to Plaintiff and secretly delivered the notes. Further, and yet
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another form of emotional manipulation, Duncan made entries in Plaintiff’s personal journal and
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requested that Plaintiff do the same in his personal journal.
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14.
Through it all, Duncan was fully aware of the inappropriate nature of his interactions
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with Plaintiff, texting Plaintiff things such as, “Be smart. I'm gonna send you an email. Don't reply to it”
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and instructing Plaintiff to “erase” and “clear” text messages between them in order to conceal his
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misconduct.
3
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1 2
15.
Duncan sent Plaintiff hundreds of text messages directly aimed at grooming and
ultimately harassing Plaintiff, including, but not limited to, the following:
3
“Do you wanna text-cry on me? I can be quiet and I'm wearing a comfortable shirt to cry on.”
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“Does he know that you have kinda adopted me as a confidant? And that you speak to me about things that you sometimes have trouble sharing with others?”
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“I am also sad when you are held away from me because I want you in my class for more
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selfish reasons. You know how I feel about you (I think you are great) and I want you
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around.”
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“I want you to know that I am your partner for this 1.5 years we have left and I care about DM about 1% as much as I care about being there for you.”
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“I being very interested in you right away.”
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“I'm glad you came along fairly early in my career.”
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“I woke up this morning and thought I wasn't going to get out of the house and I was like ‘this is it - this is it for me I'm done’ and then I did get out and I got to see u!”
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“I love you.”
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“...*huge hug that immobilizes your body* I love you so much...”
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“*whispers* I hope your Friday is better than your Thursday. I love you.”
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“*big hug* Don't reject it”
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“Back to us....I can safely say at this point that I have never been as close to student as I have
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been to you. This has happened for many reasons and I am happy to have known you so
21
well. I hope that we can keep it up (I think we can!). It is a risk to allow a student to get
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close. Can you think of any reasons why?”
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“You officially know everything about me now.”
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“I not too long ago you were having a rough night. We text hugged and you text
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cried on my shoulder. And I said something about how awesome you are and I'm sure it was
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SUPER cheesy and perhaps overly-dramatic. But it was right for that moment and it was an
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expression of my true feelings that was perfect for the context of the moment. This speech
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may come [off] as unnecessarily ionate when you look back on it someday (maybe) but
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COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
in the moment that it is presented_ it will be gold! It will feel right and the personal nature of
2
it is part of why it is persuasive.”
3
“Can you please just come live with us?”
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“Just come live with us for the rest of break.”
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“...We have literally texted every day for over 3 months. And most days prior to that going back to the start of the school year. I expect to miss you.”
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before and I think you got mad)”
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“But IF we were not close_ I almost feel like your life would be easier (I know I've said this
16.
In January 2017, Duncan ed Plaintiff’s mother, Heidi B., requesting to take
10
Plaintiff on a weekend camping trip without her parents – framing it as a “bonding” experience for
11
of the school band. Before Heidi had a chance to get back to Duncan with a response, Duncan
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sent a text message to Heidi following up about his request. Ultimately, Heidi did not allow Plaintiff to
13
attend the weekend camping trip. Nevertheless, Duncan followed up with Heidi once again attempting to
14
convince Heidi to reconsider and allow Plaintiff to attend the trip.
15
17.
In late-January 2017, realizing the strange nature of Duncan’s insistence that Plaintiff
16
attend the weekend camping trip, Plaintiff’s parents, Heidi B. and Jacob B., reviewed some of Plaintiff’s
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text messages and first discovered Duncan’s misconduct toward their minor daughter. Plaintiff’s parents
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immediately reported Duncan to the local police. Plaintiff’s parents also immediately ed several
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of PUHSD’s istration, including the school principal, regarding Duncan’s misconduct.
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18.
PUHSD deemed Duncan’s conduct as inappropriate and acknowledged that Duncan
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failed to maintain professional standards or boundaries with a minor. Nevertheless, even after Heidi and
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Jacob presented PUHSD with various forms of written evidence displaying Duncan’s misconduct,
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PUHSD allowed Duncan to return to teaching. Further, during the time period that PUHSD investigated
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Duncan’s misconduct, PUHSD perpetrated a lie to both students and parents that Duncan’s absence was
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medically related. However, in reality, Duncan was placed on istrative leave while he was being
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investigated for misconduct towards a minor.
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19.
Given PUHSD’s unprecedented decision to protect Duncan and keep him employed at
Del Oro High School, Plaintiff and her parents were faced with no option other than to remove Plaintiff
5
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
from Del Oro High School. Duncan was allowed to keep his job, but Plaintiff had to leave high school
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before the end of her junior year. Simply put, PUHSD chose Duncan over their student’s well-being and
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safety. COMPLIANCE WITH GOVERNMENT TORT CLAIMS ACT
4 5
20.
On or about May 12, 2017 Plaintiffs presented a Government Tort Claim for Damages to
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Defendant WUHSD. On June 6, 2017, Defendant PUHSD formally "rejected" Plaintiffs’ government
7
tort claim and mailed notice of the same.
8 9
21.
This complaint was filed within six months of the date when Defendant PUHSD rejected
the government tort claim. As such, Plaintiff has filed suit in a timely fashion.
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FIRST CAUSE OF ACTION
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INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
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(On Behalf of Plaintiff JANE DOE Against
13
Defendant BENJAMIN DUNCAN and DOES 31-40)
14 15 16
22.
Plaintiff re-alleges and incorporates by reference herein each and every allegation
contained herein above as though fully set forth and brought in this cause of action. 23.
Acting with knowledge of his superior position and his special relationship with
17
Plaintiff, and realizing Plaintiff’s special susceptibility to emotional distress due to Plaintiff’s age,
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inexperience, and vulnerability, Defendant DUNCAN commenced upon a course of grooming Plaintiff
19
so that he could ultimately harass her. At all times DUNCAN was a teacher and band director at
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Plaintiff's high school and he used this position to gain Plaintiff's trust and friendship, knowing that he
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could then take advantage of Plaintiff.
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24.
DUNCAN’s misconduct was outrageous, particularly because of the age difference
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between himself and Plaintiff (Plaintiff was in her mid-teens, DUNCAN was in his 30s) and because
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he was Plaintiff’s trusted mentor at the high school. DUNCAN used this trust to his advantage by
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manipulating Plaintiff's emotions and exploited her.
26
25.
DUNCAN’s acts were intentional, willful, oppressive, and malicious and done for the
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purpose of causing Plaintiff to suffer emotional harm, humiliation, mental anguish and emotional
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distress or with reckless disregard for the likelihood that he would cause Plaintiff such distress.
6
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
26.
As a direct and legal result of Defendants' actions and misconduct, Plaintiff suffered
2
and continues to suffer severe and permanent injuries including, but not limited to, physical and
3
mental pain and suffering, severe emotional distress, psychological harm, physical injuries, past and
4
future costs of medical care and treatment, and past and future loss of earnings and earning capacity,
5
and other damages in an amount not yet ascertained, but which will exceed the minimum jurisdictional
6
limits of this Court.
7
27.
In committing the acts described herein, the conduct of Defendant DUNCAN was
8
despicable, and done with malice, oppression and fraud, justifying an award of punitive damages
9
against him.
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SECOND CAUSE OF ACTION
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NEGLIGENT HIRING, SUPERVISION & RETENTION OF AN UNFIT EMPLOYEE
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(On Behalf of Plaintiff JANE DOE against Defendant PLACER UNION HIGH SCHOOL
13
DISTRICT and DOES 1-30)
14 15 16
28.
Plaintiff re-alleges and incorporates by reference herein each and every allegation
contained herein above as though fully set forth and brought in this cause of action. 29.
Defendant PUHSD had the responsibility and duty to adequately and properly
17
investigate, hire, train and supervise its teachers and staff so as to protect its students from harm
18
caused by unfit and dangerous individuals hired as teachers.
19
30.
Defendant PUHSD knew or should have known that DUNCAN was unfit to be a
20
teacher before it hired him. Had Defendant PUHSD conducted an appropriate and reasonable
21
investigation into DUNCAN’s professional background, said Defendant PUHSD would have learned
22
that UNCAN was unfit to be a teacher and would not have hired him.
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31.
Once hired, PUHSD knew, had reason to know, or was otherwise on notice, that
24
DUNCAN was harassing female students, prior to the time he harassed Plaintiff. Defendant PUHSD
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failed to take reasonable steps or implement reasonable safeguards to ensure that such misconduct did
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not occur in the future.
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32.
DUNCAN engaged in other behavior and misconduct that PUHSD knew or should
have known about, including improper texting of female students, improper relationships with female
7
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
students, and improper interactions with female students. PUHSD failed to take sufficient or
2
reasonable action to curb DUNCAN’s misconduct. In fact, even after Plaintiff’s parents, HEIDI B. and
3
JACOB B., presented PUHSD with various forms of written evidence displaying DUNCAN’s
4
misconduct toward Plaintiff, PUHSD allowed DUNCAN to continue teaching at Del Oro High School.
5
Given PUHSD’s decision to protect Duncan and keep him employed at Del Oro High School, Plaintiff
6
and her parents were faced with no option other than to remove Plaintiff from Del Oro High School. 33.
7 8
As such, Defendant PUHSD failed to exercise reasonable care in hiring, supervising
and retaining DUNCAN. 34.
9
Had Defendant PUHSD properly investigated, supervised, and monitored DUNCAN, it
10
would have learned that he was unfit to be employed as a teacher. By failing to adequately supervise,
11
monitor or investigate, Defendants allowed PUHSD to continue, unhindered, with his misconduct
12
directed towards underage students, including Plaintiff. 35.
13
Defendants PUHSD negligently hired, supervised, retained, monitored and otherwise
14
employed DUNCAN and negligently failed to ensure the safety of its minor students, including
15
Plaintiff, who were each entrusted to PUHSD’s custody, care and control. 36.
16
Had Defendant PUHSD performed their duties and responsibilities to monitor,
17
supervise, and/or investigate its teacher, Plaintiff would not have been subject to the harassment and
18
other harmful conduct inflicted upon her. 37.
19
As a direct and legal result of this conduct, Plaintiff suffered severe and permanent
20
injuries including, but not limited to, physical and mental pain and suffering, severe emotional distress,
21
psychological harm, physical injuries, past and future costs of medical care and treatment, and past
22
and future loss of earnings and earning capacity, and other damages, in an amount not yet ascertained,
23
but which exceed the minimum jurisdictional limits of this Court.
24
///
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///
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///
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THIRD CAUSE OF ACTION
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NEGLIGENT FAILURE TO WARN, TRAIN, OR EDUCATE
8
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
(On Behalf of Plaintiff JANE DOE, HEIDI B., and JACOB B.
2
against Defendant PLACER UNION HIGH SCHOOL DISTRICT AND DOES 1-30) 38.
3 4
Plaintiff re-alleges and incorporates by reference herein each and every allegation
contained herein above as though fully set forth and brought in this cause of action. 39.
5
Defendant PUHSD had a duty to warn, train and educate the students in its custody,
6
care and control, like Plaintiff, on known and knowable dangers posed by its faculty and staff.
7
Defendant PUHSD also had a duty to warn the parents of the students in its custody, care and control,
8
like HEIDI B. and JACOB B., on known and knowable dangers posed by its faculty and staff. 40.
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Defendant PUHSD also had a duty to warn, train and educate its faculty and staff on its
sexual harassment policy and inappropriate boundary crossing with students. 41.
11
Defendant PUHSD breached their duty to Plaintiff, HEIDI B., and JACOB B. by failing
12
to warn them of known and knowable dangers posed by its faculty and staff, including DUNCAN; by
13
failing to inform and educate Plaintiff on its sexual harassment policies and the methods to identify,
14
report and respond to inappropriate sexual harassment by teachers; and by failing to train its faculty,
15
including DUNCAN, on PUHSD’s sexual harassment policies. 42.
16
As a result of Defendant PUHSD having breached their duty to warn, train or educate
17
Plaintiff and her parents, HEIDI B. and JACOB B., Plaintiff was groomed, manipulated, and
18
ultimately sexually harassed by DUNCAN. 43.
19 20
Had PUHSD fulfilled their duties and responsibilities, Plaintiff, HEIDI B., and JACOB
B. would not have been injured and damaged. 44.
21
As a direct and legal result of this negligent conduct, Plaintiff, HEIDI B., and JACOB
22
B. suffered severe and permanent injuries including, but not limited to, physical and mental pain and
23
suffering, severe emotional distress, psychological harm, physical injuries, past and future costs of
24
medical care and treatment, and past and future loss of earnings and earning capacity, and other
25
damages, in an amount not yet ascertained, but which exceed the minimum jurisdictional limits of this
26
Court.
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FOURTH CAUSE OF ACTION
9
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
NEGLIGENT SUPERVISION OF A MINOR
2
(On Behalf of Plaintiff JANE DOE against
3
Defendant PLACER UNION HIGH SCHOOL DISTRICT AND DOES 1-30)
4 5 6
45.
Plaintiff re-alleges and incorporates by reference herein each and every allegation
contained herein above as though fully set forth and brought in this cause of action. 46.
Defendant PUHSD was responsible for the care, custody, control, supervision and
7
protection of the minor students entrusted to them; like Plaintiff. Thus, PUHSD had a duty to
8
adequately and properly supervise, monitor and protect Plaintiff from known and knowable dangers;
9
like DUNCAN.
10
47.
Defendant PUHSD breached their duty to properly and adequately supervise, monitor and
11
protect Plaintiff by, in part, ignoring clear and obvious signs that DUNCAN was engaged in repeated
12
inappropriate and harassing relationships with his underage female students; allowing Plaintiff to spend
13
unsupervised one-on-one time with DUNCAN; and by allowing DUNCAN to repeatedly sexually harass
14
Plaintiff on campus and during school band related activities.
15 16 17
48.
Had Defendant PUHSD adequately and properly supervised, monitored and protected its
students, Plaintiff would not have been harmed. 49.
Defendant PUHSD also recklessly and negligently failed to implement and/or enforce
18
policies or procedures that were aimed at preventing or detecting the harassment of its students which
19
fell well below the standard of care.
20 21 22
50.
Had Defendant PUHSD adequately performed their duty and responsibility, then Plaintiff
would not have been subject to the harassment as alleged herein. 51.
As a direct and proximate result of the acts and omissions of PUHSD as alleged herein,
23
Plaintiff suffered severe and permanent injuries including, but not limited to, physical and mental pain
24
and suffering, severe emotional distress, psychological harm, injuries, past and future costs of medical
25
care and treatment, and past and future loss of earnings and earning capacity, and other damages, in an
26
amount not yet ascertained, but which exceed the minimum jurisdictional limits of this Court.
27
FIFTH CAUSE OF ACTION
28
SEXUAL HARASSMENT (Civ. Code §§51.9 & 52)
10
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
(On Behalf of Plaintiff JANE DOE and Against Defendant BENJAMIN DUNCAN, PLACER
2
UNION HIGH SCHOOL DISTRICT AND DOES 1-40)
3 4 5 6 7
52.
Plaintiff re-alleges and incorporates by reference herein each and every allegation
contained herein above as though fully set forth and brought in this cause of action. 53.
Plaintiff had a teacher-student relationship with DUNCAN engaged in verbal, written,
and other conduct of a sexual nature based on her gender that were unwelcome and pervasive. 54.
DUNCAN began grooming Plaintiff with the calculated intent to gain her trust and
8
friendship so that he could ultimately sexually harass her and abuse her. DUNCAN began the
9
grooming process through constant text messages, emails, and phone calls to Plaintiff at all hours of
10
the day and night, generally starting around 5:00 a.m. in the morning and up until 2:00 a.m. at night.
11
DUNCAN exchanged thousands of deeply personal text messages with Plaintiff during the months he
12
was grooming her. DUNCAN also routinely made secret late-night phone calls to Plaintiff, which
13
often lasted hours at a time. DUNCAN also often wrote deeply personal handwritten notes to Plaintiff
14
and secretly delivered the notes. Further, and yet another form of emotional manipulation, DUNCAN
15
made entries in Plaintiff’s personal journal and requested that Plaintiff do the same in his personal
16
journal.
17 18 19
55.
There was an inability by Plaintiff to easily terminate the relationship since DUNCAN
was her teacher and band director, and Plaintiff was a minor under his care and control. 56.
Implicitly or explicitly, PUHSD aided, incited, ratified, and/or conspired in the denial
20
of Plaintiff’s right to be free from sexual harassment by her teacher and thus allowed him to repeatedly
21
sexually harass Plaintiff.
22
57.
As a direct and proximate result of the acts and omissions of Defendants PUHSD and
23
DUNCAN alleged herein, Plaintiff suffered severe and permanent injuries including, but not limited to,
24
physical and mental pain and suffering, severe emotional distress, psychological harm, physical injuries,
25
past and future costs of medical care and treatment, and past and future loss of earnings and earning
26
capacity, and other damages, in an amount not yet ascertained, but which exceed the minimum
27
jurisdictional limits of this Court.
28
58. Pursuant to Section 52 of the California Civil Code, Plaintiff also seeks exemplary damages
11
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
in an amount to be determined by the jury and attorney’s fees against said Defendants. PRAYER FOR RELIEF
2 3 4 5 6
WHEREFORE, Plaintiff JANE DOE, HEIDI B., and JACOB B. pray for judgment against Defendants, and each of them, as follows: 1. For an award of special (economic) and general (non-economic) damages according to proof;
7
2. For punitive damages against Defendants BENJAMIN DUNCAN;
8
3. Attorney’s fees against BENJAMIN DUNCAN and PLACER UNION HIGH SCHOOL
9
DISTRICT;
10
4. For costs of suit incurred herein; and
11
5. For such other and further relief as the Court deems just and proper.
12 13
Dated: November __, 2017
14
TAYLOR & RING By: David M. Ring Sonya Ostovar Attorneys for Plaintiff, JANE DOE, HEIDI B. and JACOB B.
15 16 17 18
DEMAND FOR JURY TRIAL
19 20 21
Plaintiffs hereby demands that her action be determined by trial by jury. Dated: November __, 2017
TAYLOR & RING
22 23
By: David M. Ring Sonya Ostovar Attorneys for Plaintiff, JANE DOE, HEIDI B. and JACOB B.
24 25 26 27 28
12
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
David M. Ring (SBN 151124) Sonya Ostovar (SBN 307207) TAYLOR & RING 1230 Rosecrans Avenue, Suite 360 Manhattan Beach, California 90266 Telephone: (310) 209-4100 Attorneys for Plaintiffs, JANE DOE, a minor, by and through her guardian, HEIDI B., HEIDI B., individually, and JACOB B., individually
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
FOR THE COUNTY OF PLACER
10 11 12 13
JANE DOE, a minor, by through her guardian, HEIDI B.; HEIDI B., individually; and JACOB B., individually
14
Plaintiffs,
15
-vs.-
16 17 18 19
PLACER UNION HIGH SCHOOL DISTRICT, a public entity; BENJAMIN DUNCAN, individually; and DOES 1-60, Defendants.
20 21 22 23 24
) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )
CASE NO. COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
Plaintiff, JANE DOE, a minor, by and through her guardian, HEIDI B., HEIDI B., individually, and JACOB B., individually hereby file their Complaint and complain and allege as follows:
25 26 27 28
/// /// THE PARTIES
1
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
1.
Plaintiff JANE DOE (“Plaintiff”) is currently a 16-year-old female who resides in El
2
Dorado County, California. Plaintiff was a victim of sexual harassment perpetrated by her teacher and
3
band director at Del Oro High School in Loomis, California. As such, Plaintiff's identity has been
4
concealed from public court filings in order to prevent those not directly involved in this action from
5
learning her identity and making her identity public. Such a public disclosure would further harm
6
Plaintiff.
7 8 9 10 11
2.
Plaintiff HEIDI B. is Plaintiff JANE DOE’s mother who currently resides in El Dorado
County, California. 3.
Plaintiff JACOB B. is Plaintiff JANE DOE’s father who currently resides in El Dorado
County, California. 4.
Defendant PLACER UNION HIGH SCHOOL DISTRICT (“PUHSD”) and DOES 1
12
through 10 is a public school district existing under the laws of the State of California. Its main office is
13
located at 13000 New Airport, Auburn, CA 95603.
14
5.
Defendants DOES 11-30 are s, teachers, staff, employees and agents of
15
Defendant PUHSD who owed a duty of care to Plaintiff and breached that duty of care, as described in
16
more detail herein.
17
6.
Del Oro High School is a high school operated by and under the control of Defendant
18
PUHSD, its governing school board, superintendent, s, and employees. Del Oro High
19
School is located at 3301 Taylor Rd, Loomis, CA 95650.
20
7.
Defendant BENJAMIN DUNCAN and DOES 31-40 was a resident of Placer County,
21
California. DUNCAN’s misconduct toward Plaintiff, includes sexual harassment, interference with the
22
education of a minor, and other tortious misconduct during the 2015-2016 and 2016-2017 school year
23
when Plaintiff was approximately 14-16 years old. At the time, DUNCAN was in his mid-30s.
24
8.
Jurisdiction is proper in Placer County because the defendants are either residents of
25
Placer County or do business in Placer County, and also because the acts which are the basis of this
26
lawsuit occurred in Placer County.
27 28
9.
The true names and capacities of each defendant designated herein as DOES 1 through
60, whether an individual, business, public entity, or some other entity, are presently unknown to
2
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
Plaintiff, who therefore sues said defendants by such fictitious names, pursuant to Code of Civil
2
Procedure section 474. Each DOE defendant is responsible in some actionable manner for the events
3
alleged herein. Plaintiff will amend the Complaint to state the true names and capacities of said
4
defendants when the same have been ascertained.
5
10.
Each of the defendants sued herein as DOES 1 through 60 was the agent and employee of
6
each of the remaining defendants and was at all times acting within the course and scope of such agency
7
and employment with the full knowledge, consent, authority, ratification and/or permission of each of
8
the remaining defendants.
9 10
11.
them, is intended to include, and shall be deemed to include, all fictitiously named defendants. GENERAL ALLEGATIONS
11 12 13 14
Wherever appearing in this complaint, each and every reference to Defendants, or any of
12.
Plaintiff was 14 years old when she entered the tenth grade for the 2015-2016 school year
at Del Oro High School. Defendant Benjamin Duncan was Plaintiff’s teacher and school band director. 13.
Soon after the school year began, Duncan began “grooming” Plaintiff with the calculated
15
intent to gain her trust and friendship beyond what would be considered a “normal” teacher-student
16
relationship. Duncan’s intent for doing so was and remains unclear. But, his actions in doing so were far
17
beyond any normal boundaries between a teacher and student. Duncan began the grooming process
18
through constant text messages, emails, and phone calls to Plaintiff at all hours of the day and night,
19
generally starting around 5:00 a.m. in the morning and up until 2:00 a.m. at night. Duncan exchanged
20
thousands of personal text messages with Plaintiff during the months he was grooming her. Duncan also
21
routinely made secret late-night phone calls to Plaintiff, which often lasted hours at a time. Duncan also
22
often wrote personal handwritten notes to Plaintiff and secretly delivered the notes. Further, and yet
23
another form of emotional manipulation, Duncan made entries in Plaintiff’s personal journal and
24
requested that Plaintiff do the same in his personal journal.
25
14.
Through it all, Duncan was fully aware of the inappropriate nature of his interactions
26
with Plaintiff, texting Plaintiff things such as, “Be smart. I'm gonna send you an email. Don't reply to it”
27
and instructing Plaintiff to “erase” and “clear” text messages between them in order to conceal his
28
misconduct.
3
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1 2
15.
Duncan sent Plaintiff hundreds of text messages directly aimed at grooming and
ultimately harassing Plaintiff, including, but not limited to, the following:
3
“Do you wanna text-cry on me? I can be quiet and I'm wearing a comfortable shirt to cry on.”
4
“Does he know that you have kinda adopted me as a confidant? And that you speak to me about things that you sometimes have trouble sharing with others?”
5 6
“I am also sad when you are held away from me because I want you in my class for more
7
selfish reasons. You know how I feel about you (I think you are great) and I want you
8
around.”
9
“I want you to know that I am your partner for this 1.5 years we have left and I care about DM about 1% as much as I care about being there for you.”
10 11
“I being very interested in you right away.”
12
“I'm glad you came along fairly early in my career.”
13
“I woke up this morning and thought I wasn't going to get out of the house and I was like ‘this is it - this is it for me I'm done’ and then I did get out and I got to see u!”
14 15
“I love you.”
16
“...*huge hug that immobilizes your body* I love you so much...”
17
“*whispers* I hope your Friday is better than your Thursday. I love you.”
18
“*big hug* Don't reject it”
19
“Back to us....I can safely say at this point that I have never been as close to student as I have
20
been to you. This has happened for many reasons and I am happy to have known you so
21
well. I hope that we can keep it up (I think we can!). It is a risk to allow a student to get
22
close. Can you think of any reasons why?”
23
“You officially know everything about me now.”
24
“I not too long ago you were having a rough night. We text hugged and you text
25
cried on my shoulder. And I said something about how awesome you are and I'm sure it was
26
SUPER cheesy and perhaps overly-dramatic. But it was right for that moment and it was an
27
expression of my true feelings that was perfect for the context of the moment. This speech
28
may come [off] as unnecessarily ionate when you look back on it someday (maybe) but
4
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
in the moment that it is presented_ it will be gold! It will feel right and the personal nature of
2
it is part of why it is persuasive.”
3
“Can you please just come live with us?”
4
“Just come live with us for the rest of break.”
5
“...We have literally texted every day for over 3 months. And most days prior to that going back to the start of the school year. I expect to miss you.”
6 7
before and I think you got mad)”
8 9
“But IF we were not close_ I almost feel like your life would be easier (I know I've said this
16.
In January 2017, Duncan ed Plaintiff’s mother, Heidi B., requesting to take
10
Plaintiff on a weekend camping trip without her parents – framing it as a “bonding” experience for
11
of the school band. Before Heidi had a chance to get back to Duncan with a response, Duncan
12
sent a text message to Heidi following up about his request. Ultimately, Heidi did not allow Plaintiff to
13
attend the weekend camping trip. Nevertheless, Duncan followed up with Heidi once again attempting to
14
convince Heidi to reconsider and allow Plaintiff to attend the trip.
15
17.
In late-January 2017, realizing the strange nature of Duncan’s insistence that Plaintiff
16
attend the weekend camping trip, Plaintiff’s parents, Heidi B. and Jacob B., reviewed some of Plaintiff’s
17
text messages and first discovered Duncan’s misconduct toward their minor daughter. Plaintiff’s parents
18
immediately reported Duncan to the local police. Plaintiff’s parents also immediately ed several
19
of PUHSD’s istration, including the school principal, regarding Duncan’s misconduct.
20
18.
PUHSD deemed Duncan’s conduct as inappropriate and acknowledged that Duncan
21
failed to maintain professional standards or boundaries with a minor. Nevertheless, even after Heidi and
22
Jacob presented PUHSD with various forms of written evidence displaying Duncan’s misconduct,
23
PUHSD allowed Duncan to return to teaching. Further, during the time period that PUHSD investigated
24
Duncan’s misconduct, PUHSD perpetrated a lie to both students and parents that Duncan’s absence was
25
medically related. However, in reality, Duncan was placed on istrative leave while he was being
26
investigated for misconduct towards a minor.
27 28
19.
Given PUHSD’s unprecedented decision to protect Duncan and keep him employed at
Del Oro High School, Plaintiff and her parents were faced with no option other than to remove Plaintiff
5
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
from Del Oro High School. Duncan was allowed to keep his job, but Plaintiff had to leave high school
2
before the end of her junior year. Simply put, PUHSD chose Duncan over their student’s well-being and
3
safety. COMPLIANCE WITH GOVERNMENT TORT CLAIMS ACT
4 5
20.
On or about May 12, 2017 Plaintiffs presented a Government Tort Claim for Damages to
6
Defendant WUHSD. On June 6, 2017, Defendant PUHSD formally "rejected" Plaintiffs’ government
7
tort claim and mailed notice of the same.
8 9
21.
This complaint was filed within six months of the date when Defendant PUHSD rejected
the government tort claim. As such, Plaintiff has filed suit in a timely fashion.
10
FIRST CAUSE OF ACTION
11
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
12
(On Behalf of Plaintiff JANE DOE Against
13
Defendant BENJAMIN DUNCAN and DOES 31-40)
14 15 16
22.
Plaintiff re-alleges and incorporates by reference herein each and every allegation
contained herein above as though fully set forth and brought in this cause of action. 23.
Acting with knowledge of his superior position and his special relationship with
17
Plaintiff, and realizing Plaintiff’s special susceptibility to emotional distress due to Plaintiff’s age,
18
inexperience, and vulnerability, Defendant DUNCAN commenced upon a course of grooming Plaintiff
19
so that he could ultimately harass her. At all times DUNCAN was a teacher and band director at
20
Plaintiff's high school and he used this position to gain Plaintiff's trust and friendship, knowing that he
21
could then take advantage of Plaintiff.
22
24.
DUNCAN’s misconduct was outrageous, particularly because of the age difference
23
between himself and Plaintiff (Plaintiff was in her mid-teens, DUNCAN was in his 30s) and because
24
he was Plaintiff’s trusted mentor at the high school. DUNCAN used this trust to his advantage by
25
manipulating Plaintiff's emotions and exploited her.
26
25.
DUNCAN’s acts were intentional, willful, oppressive, and malicious and done for the
27
purpose of causing Plaintiff to suffer emotional harm, humiliation, mental anguish and emotional
28
distress or with reckless disregard for the likelihood that he would cause Plaintiff such distress.
6
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
26.
As a direct and legal result of Defendants' actions and misconduct, Plaintiff suffered
2
and continues to suffer severe and permanent injuries including, but not limited to, physical and
3
mental pain and suffering, severe emotional distress, psychological harm, physical injuries, past and
4
future costs of medical care and treatment, and past and future loss of earnings and earning capacity,
5
and other damages in an amount not yet ascertained, but which will exceed the minimum jurisdictional
6
limits of this Court.
7
27.
In committing the acts described herein, the conduct of Defendant DUNCAN was
8
despicable, and done with malice, oppression and fraud, justifying an award of punitive damages
9
against him.
10
SECOND CAUSE OF ACTION
11
NEGLIGENT HIRING, SUPERVISION & RETENTION OF AN UNFIT EMPLOYEE
12
(On Behalf of Plaintiff JANE DOE against Defendant PLACER UNION HIGH SCHOOL
13
DISTRICT and DOES 1-30)
14 15 16
28.
Plaintiff re-alleges and incorporates by reference herein each and every allegation
contained herein above as though fully set forth and brought in this cause of action. 29.
Defendant PUHSD had the responsibility and duty to adequately and properly
17
investigate, hire, train and supervise its teachers and staff so as to protect its students from harm
18
caused by unfit and dangerous individuals hired as teachers.
19
30.
Defendant PUHSD knew or should have known that DUNCAN was unfit to be a
20
teacher before it hired him. Had Defendant PUHSD conducted an appropriate and reasonable
21
investigation into DUNCAN’s professional background, said Defendant PUHSD would have learned
22
that UNCAN was unfit to be a teacher and would not have hired him.
23
31.
Once hired, PUHSD knew, had reason to know, or was otherwise on notice, that
24
DUNCAN was harassing female students, prior to the time he harassed Plaintiff. Defendant PUHSD
25
failed to take reasonable steps or implement reasonable safeguards to ensure that such misconduct did
26
not occur in the future.
27 28
32.
DUNCAN engaged in other behavior and misconduct that PUHSD knew or should
have known about, including improper texting of female students, improper relationships with female
7
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
students, and improper interactions with female students. PUHSD failed to take sufficient or
2
reasonable action to curb DUNCAN’s misconduct. In fact, even after Plaintiff’s parents, HEIDI B. and
3
JACOB B., presented PUHSD with various forms of written evidence displaying DUNCAN’s
4
misconduct toward Plaintiff, PUHSD allowed DUNCAN to continue teaching at Del Oro High School.
5
Given PUHSD’s decision to protect Duncan and keep him employed at Del Oro High School, Plaintiff
6
and her parents were faced with no option other than to remove Plaintiff from Del Oro High School. 33.
7 8
As such, Defendant PUHSD failed to exercise reasonable care in hiring, supervising
and retaining DUNCAN. 34.
9
Had Defendant PUHSD properly investigated, supervised, and monitored DUNCAN, it
10
would have learned that he was unfit to be employed as a teacher. By failing to adequately supervise,
11
monitor or investigate, Defendants allowed PUHSD to continue, unhindered, with his misconduct
12
directed towards underage students, including Plaintiff. 35.
13
Defendants PUHSD negligently hired, supervised, retained, monitored and otherwise
14
employed DUNCAN and negligently failed to ensure the safety of its minor students, including
15
Plaintiff, who were each entrusted to PUHSD’s custody, care and control. 36.
16
Had Defendant PUHSD performed their duties and responsibilities to monitor,
17
supervise, and/or investigate its teacher, Plaintiff would not have been subject to the harassment and
18
other harmful conduct inflicted upon her. 37.
19
As a direct and legal result of this conduct, Plaintiff suffered severe and permanent
20
injuries including, but not limited to, physical and mental pain and suffering, severe emotional distress,
21
psychological harm, physical injuries, past and future costs of medical care and treatment, and past
22
and future loss of earnings and earning capacity, and other damages, in an amount not yet ascertained,
23
but which exceed the minimum jurisdictional limits of this Court.
24
///
25
///
26
///
27
THIRD CAUSE OF ACTION
28
NEGLIGENT FAILURE TO WARN, TRAIN, OR EDUCATE
8
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
(On Behalf of Plaintiff JANE DOE, HEIDI B., and JACOB B.
2
against Defendant PLACER UNION HIGH SCHOOL DISTRICT AND DOES 1-30) 38.
3 4
Plaintiff re-alleges and incorporates by reference herein each and every allegation
contained herein above as though fully set forth and brought in this cause of action. 39.
5
Defendant PUHSD had a duty to warn, train and educate the students in its custody,
6
care and control, like Plaintiff, on known and knowable dangers posed by its faculty and staff.
7
Defendant PUHSD also had a duty to warn the parents of the students in its custody, care and control,
8
like HEIDI B. and JACOB B., on known and knowable dangers posed by its faculty and staff. 40.
9 10
Defendant PUHSD also had a duty to warn, train and educate its faculty and staff on its
sexual harassment policy and inappropriate boundary crossing with students. 41.
11
Defendant PUHSD breached their duty to Plaintiff, HEIDI B., and JACOB B. by failing
12
to warn them of known and knowable dangers posed by its faculty and staff, including DUNCAN; by
13
failing to inform and educate Plaintiff on its sexual harassment policies and the methods to identify,
14
report and respond to inappropriate sexual harassment by teachers; and by failing to train its faculty,
15
including DUNCAN, on PUHSD’s sexual harassment policies. 42.
16
As a result of Defendant PUHSD having breached their duty to warn, train or educate
17
Plaintiff and her parents, HEIDI B. and JACOB B., Plaintiff was groomed, manipulated, and
18
ultimately sexually harassed by DUNCAN. 43.
19 20
Had PUHSD fulfilled their duties and responsibilities, Plaintiff, HEIDI B., and JACOB
B. would not have been injured and damaged. 44.
21
As a direct and legal result of this negligent conduct, Plaintiff, HEIDI B., and JACOB
22
B. suffered severe and permanent injuries including, but not limited to, physical and mental pain and
23
suffering, severe emotional distress, psychological harm, physical injuries, past and future costs of
24
medical care and treatment, and past and future loss of earnings and earning capacity, and other
25
damages, in an amount not yet ascertained, but which exceed the minimum jurisdictional limits of this
26
Court.
27 28
FOURTH CAUSE OF ACTION
9
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
NEGLIGENT SUPERVISION OF A MINOR
2
(On Behalf of Plaintiff JANE DOE against
3
Defendant PLACER UNION HIGH SCHOOL DISTRICT AND DOES 1-30)
4 5 6
45.
Plaintiff re-alleges and incorporates by reference herein each and every allegation
contained herein above as though fully set forth and brought in this cause of action. 46.
Defendant PUHSD was responsible for the care, custody, control, supervision and
7
protection of the minor students entrusted to them; like Plaintiff. Thus, PUHSD had a duty to
8
adequately and properly supervise, monitor and protect Plaintiff from known and knowable dangers;
9
like DUNCAN.
10
47.
Defendant PUHSD breached their duty to properly and adequately supervise, monitor and
11
protect Plaintiff by, in part, ignoring clear and obvious signs that DUNCAN was engaged in repeated
12
inappropriate and harassing relationships with his underage female students; allowing Plaintiff to spend
13
unsupervised one-on-one time with DUNCAN; and by allowing DUNCAN to repeatedly sexually harass
14
Plaintiff on campus and during school band related activities.
15 16 17
48.
Had Defendant PUHSD adequately and properly supervised, monitored and protected its
students, Plaintiff would not have been harmed. 49.
Defendant PUHSD also recklessly and negligently failed to implement and/or enforce
18
policies or procedures that were aimed at preventing or detecting the harassment of its students which
19
fell well below the standard of care.
20 21 22
50.
Had Defendant PUHSD adequately performed their duty and responsibility, then Plaintiff
would not have been subject to the harassment as alleged herein. 51.
As a direct and proximate result of the acts and omissions of PUHSD as alleged herein,
23
Plaintiff suffered severe and permanent injuries including, but not limited to, physical and mental pain
24
and suffering, severe emotional distress, psychological harm, injuries, past and future costs of medical
25
care and treatment, and past and future loss of earnings and earning capacity, and other damages, in an
26
amount not yet ascertained, but which exceed the minimum jurisdictional limits of this Court.
27
FIFTH CAUSE OF ACTION
28
SEXUAL HARASSMENT (Civ. Code §§51.9 & 52)
10
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
(On Behalf of Plaintiff JANE DOE and Against Defendant BENJAMIN DUNCAN, PLACER
2
UNION HIGH SCHOOL DISTRICT AND DOES 1-40)
3 4 5 6 7
52.
Plaintiff re-alleges and incorporates by reference herein each and every allegation
contained herein above as though fully set forth and brought in this cause of action. 53.
Plaintiff had a teacher-student relationship with DUNCAN engaged in verbal, written,
and other conduct of a sexual nature based on her gender that were unwelcome and pervasive. 54.
DUNCAN began grooming Plaintiff with the calculated intent to gain her trust and
8
friendship so that he could ultimately sexually harass her and abuse her. DUNCAN began the
9
grooming process through constant text messages, emails, and phone calls to Plaintiff at all hours of
10
the day and night, generally starting around 5:00 a.m. in the morning and up until 2:00 a.m. at night.
11
DUNCAN exchanged thousands of deeply personal text messages with Plaintiff during the months he
12
was grooming her. DUNCAN also routinely made secret late-night phone calls to Plaintiff, which
13
often lasted hours at a time. DUNCAN also often wrote deeply personal handwritten notes to Plaintiff
14
and secretly delivered the notes. Further, and yet another form of emotional manipulation, DUNCAN
15
made entries in Plaintiff’s personal journal and requested that Plaintiff do the same in his personal
16
journal.
17 18 19
55.
There was an inability by Plaintiff to easily terminate the relationship since DUNCAN
was her teacher and band director, and Plaintiff was a minor under his care and control. 56.
Implicitly or explicitly, PUHSD aided, incited, ratified, and/or conspired in the denial
20
of Plaintiff’s right to be free from sexual harassment by her teacher and thus allowed him to repeatedly
21
sexually harass Plaintiff.
22
57.
As a direct and proximate result of the acts and omissions of Defendants PUHSD and
23
DUNCAN alleged herein, Plaintiff suffered severe and permanent injuries including, but not limited to,
24
physical and mental pain and suffering, severe emotional distress, psychological harm, physical injuries,
25
past and future costs of medical care and treatment, and past and future loss of earnings and earning
26
capacity, and other damages, in an amount not yet ascertained, but which exceed the minimum
27
jurisdictional limits of this Court.
28
58. Pursuant to Section 52 of the California Civil Code, Plaintiff also seeks exemplary damages
11
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
1
in an amount to be determined by the jury and attorney’s fees against said Defendants. PRAYER FOR RELIEF
2 3 4 5 6
WHEREFORE, Plaintiff JANE DOE, HEIDI B., and JACOB B. pray for judgment against Defendants, and each of them, as follows: 1. For an award of special (economic) and general (non-economic) damages according to proof;
7
2. For punitive damages against Defendants BENJAMIN DUNCAN;
8
3. Attorney’s fees against BENJAMIN DUNCAN and PLACER UNION HIGH SCHOOL
9
DISTRICT;
10
4. For costs of suit incurred herein; and
11
5. For such other and further relief as the Court deems just and proper.
12 13
Dated: November __, 2017
14
TAYLOR & RING By: David M. Ring Sonya Ostovar Attorneys for Plaintiff, JANE DOE, HEIDI B. and JACOB B.
15 16 17 18
DEMAND FOR JURY TRIAL
19 20 21
Plaintiffs hereby demands that her action be determined by trial by jury. Dated: November __, 2017
TAYLOR & RING
22 23
By: David M. Ring Sonya Ostovar Attorneys for Plaintiff, JANE DOE, HEIDI B. and JACOB B.
24 25 26 27 28
12
COMPLAINT FOR PERSONAL INJURIES AND DAMAGES
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