An Illinois Federal court, in Sterling v. Board of Education of Evanston Twp. High School District 202, would not allow a student to pursue Title IX or 14th Amendment claims against district administrators who allegedly ignored her prolonged sexual abuse by two school safety officers. The court found that “conclusory allegations” that two administrators knew about the sexual abuse by district employees were not enough to make them liable for the abuse – the parents had to be able to prove that the administrators knew about the abuse when it was happening and neglected to take action.

