In Doe v. Lorena Indep. Sch. Dist. (May 20, 2024), the U.S. District Court for the Western District of Texas, Waco Division grappled with a case involving a pre-kindergarten student identified as Jane Doe (Doe). Doe and another student, identified as “Student A” attended school in the Lorena Independent School District. Jeffrey C. Manske, a U.S. Magistrate Judge, recommended that the Lorena Independent School District’s Motion for Partial Dismissal under Rule 12(b)(6) be denied. The facts underlying the case are shocking and unsettling, involving allegations of sexual abuse of two little girls by a substitute teacher.

April Jewell, Lorena Primary School’s principal, was sued by Doe’s parents. The Does alleged that Doe was sexually abused at school during the 2020-2021 school year by a substitute teacher, Nicholas Crenshaw. The suit was based on violations of 42 U.S.C. Section 1983 and Title IX. Doe, then five years old, was assigned to a pre-kindergarten class. Crenshaw was a long-time substitute teacher, assigned to that classroom. Prior to October 2020, Crenshaw’s habit of lying under a blanket at naptime with Doe was condoned by Stephanie Heslep, who was the primary teacher assigned to the room. During naptime, the lights were turned off and many students slept.