Reported / Citable
Background
Jane Doe alleged that, while she was a minor attending Azle High School, teacher and assistant coach Carlos Alberto Font Santiago exchanged sexually explicit electronic messages with her from approximately fall 2021 through mid-spring 2023. She also alleged that they engaged in sexual activity in his classroom at least three times per week from fall 2021 through May 2022.
According to the complaint, coaches Mitzi Marquardt and Bert Trevino warned Font Santiago in early 2022 to maintain a safe distance from female students. Font Santiago then met with athletic director Rebecca Spurlock, and Spurlock separately met with Marquardt. Doe alleged that Spurlock failed to investigate or discipline Font Santiago. After another student reported inappropriate messages in April 2025, Doe told her parents, who contacted police. Doe later sued AISD under Title IX, sued Spurlock and Font Santiago under 42 U.S.C. § 1983, and asserted an assault claim against Font Santiago.
The Court’s Holding
The court granted Spurlock’s motion to dismiss because the complaint did not plausibly allege that she subjectively knew facts pointing plainly toward Font Santiago’s sexual abuse or a substantial risk of such abuse. Allegations that meetings occurred, that Font Santiago had possible boundary issues, or that administrators knew of a “relationship” did not identify what Spurlock was told or establish that she actually inferred inappropriate sexual conduct. Because Doe did not adequately plead the knowledge element, the court did not address deliberate indifference or constitutional injury.
The court likewise granted AISD’s motion to dismiss. Even assuming Spurlock qualified as an appropriate person under Title IX, the same factual deficiency prevented a reasonable inference that she had actual notice of ongoing abuse or a substantial risk of abuse. Both dismissals were without prejudice, and the court allowed Doe 21 days to amend because additional facts about the alleged conversations and the administration’s knowledge might cure the deficiencies. The order warned that failure to amend within that period would result in dismissal with prejudice.
Key Takeaways
- A school official’s access to information or awareness of generalized boundary concerns does not, without more, plausibly establish subjective knowledge of sexual abuse for a supervisory-liability claim under Section 1983.
- Title IX liability requires actual notice: an appropriate official must know facts showing harassment or a substantial risk of sexual abuse and must actually draw that inference.
- The court permitted amendment because more specific allegations about what Spurlock learned during the separate conversations could potentially establish the required knowledge.
Why It Matters
The decision underscores the demanding knowledge standard governing school sexual-abuse claims under both Title IX and Section 1983 in the Fifth Circuit. A complaint must specify what an authorized official learned and allege facts supporting the inference that the official actually recognized abuse or its substantial risk; vague references to boundary issues, meetings, or a close relationship are insufficient.
The dismissal was not a final merits determination. Doe received an opportunity to plead additional facts connecting the reported concerns to Spurlock’s alleged knowledge before the court considers the remaining elements of the claims challenged in these motions.