Franklin vs. Gwinnett County Public Schools

Case Study #2 : Franklin vs. Gwinnett County Public Schools

1.) Name of the Defendant: North Gwinnett High School 2.) Name of the Plaintiff: Christine Franklin

3.) Name of the court: Supreme Court

4.) Date of the Decision: February 26, 1992

5.) Summary of the facts of the case:

Breaking down the case being highlighted here, Christine Franklin was a sophomore at North Gwinnett High School back in 1986. While attending that year, she claimed to have been sexually harassed by Andrew Hill, who was a coach at the school. Franklin claimed sexual activity was unsolicited and that Hill forced her into such acts. Hill was accused of engaging her in sexual conversation, in which he asked her of her experiences with her boyfriend and if she would consider having intercourse with an older man. Hill was stated to have kissed her forcefully, calling her at home, asking her to meet him socially, asking other teachers to have her excused from their classes. Most notably, he took her into a private office and subjected her to coercive intercourse.

Despite being aware of all of this, the after school officials did not take action, which led Franklin to feeling hopeless about pressing any further charges. With the condition that all charges be dropped, Hill resigned from the school, but Franklin still filed a suit against the Gwinnett County School System, by which she wanted to be compensated with monetary damages for the harassment she went through. The suit was denied by the lower courts and cited Drayden v. Needville Independent School District as the precedent for not being able to use Title IX to pay out the damages.

When this case went to the Supreme Court, it reversed the decision of the lower courts and ruled that Title IX allows for monetary damages to be awarded in a case where legal rights have been violated, using Cannon v. University of Chicago, which states, “Where legal rights have been invaded, and a federal statute provides for a general right to sue for such invasion, federal courts may use any available remedy to make good the wrong done.”

6.) Issues to be Decided:

Should Franklin be granted monetary compensation for being sexually harassed by Hill?
How is it determined how much she gets?
How is Title IX used to defend Franklin in this case?

Is Title IX limited to back pay?

Did Congress intend to limit application of the general principle in the enforcement of Title IX?

7.) Decision of the Court: Supreme Court reversed the decision of the lower courts and allowed Franklin to collect compensation from Gwinnett Valley Public School district for being sexually harassed by Hall, a former coach and teacher employed by the district.

8.) Reasoning: Citing Cannon v. University of Chicago, the Supreme Court used the case as a precedent, which stated: “Where legal rights have been invaded, and a federal statute provides for a general right to sue for such invasion, federal courts may use any available remedy to make good the wrong done.” The courts found that they could use Title IX, because Hill’s actions caused Franklin from participating in educational opportunities.

9.) Managerial Implications

Allowing Hill to be able to resign so that he does not have to face the charges, does not put North Gwinnett High School and the Gwinnett School District in the best light, because it basically shows that any of their personnel are welcome to violate a student as long as they’re willing to quit, so that they don’t have to face the consequences.

Considering that Franklin had made others known of the issue, but failed to take action is something that would have to be addressed not only through the school, but throughout the entire district. A better system for students to report incidents in a confidential manner would have to be put in place.

Even at a school where a student is not receiving financial aid, they are still covered under Title IX. Schools need to educate their personnel on how important it is to not disrupt a student’s learning experience by any means.
If a teacher must speak with a student while that student is in another class or at home, protocols need to be better organized so that nothing remotely close to Franklin’s experience happens to anyone else—All communication with a student and teacher outside of that teacher’s class should be documented no matter the purpose for the conversation.