In a published decision, Doe 1 v. City View Indep. Sch. Dist., 145 F.4th 584, 587 (5th Cir. 2025), the Fifth Circuit Court of Appeals recently determined a student’s Title IX suit alleging sexual misconduct was barred by the statute of limitations. Jane Doe attended high school in the City View Independent School District from 2016 to 2020. During her freshman year, she alleges that a teacher and coach at the school began emotionally and sexually abusing her. The abuse reportedly continued until her graduation. More than two years after leaving school, Doe filed a federal lawsuit against the school district and several officials, claiming they had covered up the abuse and failed to protect her. She brought claims under Title IX and various constitutional amendments.
The district court reviewed Doe’s second amended complaint and dismissed it with prejudice. It found that her Title IX, Fourth Amendment, and Fourteenth Amendment claims were barred by Texas’s two-year statute of limitations for personal injury actions. The court also ruled that her First Amendment claim failed to allege a constitutional violation. Although Doe requested permission to file another amended complaint, the court did not address that request and closed the case. Doe appealed, focusing solely on the dismissal of her Title IX claims.
Under federal law, a claim accrues when the plaintiff becomes aware of the injury and its connection to the defendant’s actions. Because Doe was a minor during the alleged abuse, Texas law tolled the limitations period until she turned eighteen in February 2020. The court determined that her claims accrued no later than May 2020, when the abuse ended. Therefore, she had until May 2022 to file her lawsuit. Since she filed in April 2023, her claims were time-barred.
Doe also attempted to reframe a separate incident—a 2022 letter from a school official threatening legal action—as a Title IX retaliation claim. However, the court found that she had originally pleaded it as a First Amendment claim and had waived that argument on appeal. She failed to properly assert or support a Title IX retaliation claim based on the letter, and the appellate court declined to consider it.
Finally, Doe argued that her claims should be preserved under equitable tolling or the continuing violation doctrine. The court rejected both arguments. She did not invoke Texas-specific tolling rules, and the continuing violation doctrine did not apply because her claims involved discrete acts that ended before her graduation. The court concluded that her graduation marked a clear end to the alleged violations, and affirmed the district court’s dismissal of her case.
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