A public school district rehired a teacher despite prior concerns about inappropriate relationships with students. During his earlier employment, the teacher had engaged in questionable conduct, including socializing with students outside of school and forming a romantic relationship with a former student. Although some school board members raised concerns during the rehiring process, the board ultimately voted to bring him back.
After returning to the classroom, the teacher continued to exhibit troubling behavior, including attending student parties and making inappropriate comments. Eventually, he initiated contact with a student through text messages, which escalated into sexual solicitation and physical contact. The student’s family discovered the communications and reported the abuse to law enforcement, leading to the teacher’s criminal conviction.
The student later filed a civil lawsuit against the school district, alleging that it had acted with deliberate indifference by rehiring the teacher despite his known history. A jury found in favor of the student and awarded $250,000 in damages. On appeal, the court upheld the verdict, concluding that the district had failed to adequately protect students and was liable under federal law.
The appellate court affirmed the district court’s denial of a school district’s motion for judgment as a matter of law in a civil rights case brought under 42 U.S.C. § 1983. The plaintiff alleged that the district’s decision to rehire a teacher with a known history of inappropriate conduct was the “moving force” behind the constitutional injury suffered. The jury found sufficient evidence of causation, noting that the teacher had previously engaged in similar misconduct and that his rehiring directly led to the abuse. The court concluded that the jury’s finding was supported by the record and consistent with precedent requiring a strong connection between the policy decision and the resulting harm.
The court also upheld the jury’s finding of deliberate indifference by the school board. Evidence showed that trustees were aware of prior allegations involving the teacher’s relationships with students, including concerns raised during board meetings and social media posts suggesting inappropriate behavior. Despite this knowledge, the board voted to rehire the teacher. The court determined that a reasonable jury could conclude the board disregarded a known risk of harm, satisfying the legal standard for municipal liability under § 1983. As a result, the judgment in favor of the plaintiff was affirmed.
The case is Loera v. Kingsville Indep. Sch. Dist., No. 24-40481, 2025 WL 2425186 (5th Cir. Aug. 22, 2025).
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