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IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF MICHIGAN

JANE DOE, A MINOR
Plaintiff,
v.
LANSING PUBLIC SCHOOLS,
YVONNE CAAMAL CANUL,
Superintendent, in her Official and Individual Capacities;
DONNA POHL,
Principal, in her Official and Individual Capacities;
GLENN STEVENS,
Assistant Principal, in his Official and Individual Capacities;
SHARON MCWILLIAMS,
Student Services Specialist, in her Official and Individual Capacities;
WILLIE ROGERS,
Public Safety Officer, in his Official and Individual Capacities,

Defendants.
______________________________________ /
Karen Truskowski (P56929)
Temperance Legal Group PLLC
530 Mall Court #131
Lansing, MI 48912
517.235.3053 phone
347.412.6081 fax
Attorney for Plaintiff
COMPLAINT AND JURY DEMAND
This cause of action arises from Defendants’ deliberately indifferent response to a student-on-student
sexual assault on school premises and subsequent sex-based harassment. Defendants’ failure to promptly
and appropriately investigate and respond to the assault subjected Plaintiff to further sexual harassment
and a hostile environment, effectively denying her access to educational opportunities. This action
alleges violations of Title IX and the denial of equal protection of the laws under the Fourteenth
Amendment to the U.S. Constitution.

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Plaintiff, Jane Doe,1 by and through her attorney, KAREN TRUSZKOWSKI, hereby files the
following complaint against Defendants as captioned above.
I. JURISDICTION AND VENUE
1. This Court has subject matter jurisdiction over this case pursuant to 28 U.S.C. § 1331, which
gives district courts jurisdiction over all civil actions arising under the Constitution, laws, and treaties of
the United States.
2. This Court also has subject matter jurisdiction pursuant to 28 U.S.C. § 1343, which gives
district courts original jurisdiction over (a) any civil action authorized by law to be brought by any person
to redress the deprivation, under color of any State Law, statute, ordinance, regulation, custom or usage,
of any right, privilege or immunity secured by the Constitution of the United States or by any Act of
Congress providing for equal rights of citizens or of all persons within the jurisdiction of the United
States; and (b) any civil action to recover damages or to secure equitable relief under any Act of Congress
providing for the protection of the civil rights.
3. Plaintiff brings this action to redress a hostile educational environment pursuant to Title IX of
the Education Amendments of 1972, 20 U.S.C. § 1681(a), as more fully set forth herein.
4. This is also an action to redress the deprivation of Plaintiff’s constitutional rights under the
Fourteenth Amendment of the United States Constitution pursuant to 42 U.S.C. § 1983.
5. Venue is proper in this district pursuant to 28 U.S.C. § 1391(b), since all defendants reside or
resided in this district and the events giving rise to the claims occurred in this district.
II. THE PARTIES
6. Plaintiff (“Jane Doe”) was a 14-year-old female at the time of the incident that is the subject of
this complaint.
7. At all material times Plaintiff was a resident of Ingham County, State of Michigan.

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”Jane Doe” has been substituted for Plaintiff’s name for all causes of action brought through this Complaint. Plaintiff was a
minor at the time of the sexual assault and is a minor at the time of the filing of the within matter

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8. At the time of events complained of herein, Plaintiff was a student attending a high school
within the Defendant LANSING PUBLIC SCHOOLS. (“The School District”.)
9. The Defendant School District is a public educational institution located in Ingham County,
State of Michigan.
10. At all material times, Defendant YVONNE CAAMAL CANUL (“Canul,”) in her official and
individual capacities, worked within the County of Ingham, State of Michigan.
11. During all material times, Canul was an agent and/or employee of Defendant School District,
acting or failing to act within the scope, course, and authority of her employment and her employer.
12. At all material times, DONNA POHL, (“Pohl”), in her official and individual capacities,
worked within the County of Ingham, State of Michigan.
13. During all material times, Pohl was an agent and/or employee of Defendant School District,
acting or failing to act within the scope, course, and authority of her employment and her employer.
14. At all material times, Defendant Assistant Principal GLENN STEVENS, (“Stevens”) in his
official and individual capacities, worked within Ingham County, State of Michigan.
15. At all material times, Stevens was an agent and/or employee of Defendant School District,
acting or failing to act within the scope, course, and authority of his employment and his employer.
16. At all material times, Defendant Student Services Specialist SHARON MCWILLIAMS,
(“McWilliams”) in her official and individual capacities, worked within Ingham County, State of
Michigan.
17. At all material times, McWilliams was an agent and/or employee of Defendant School
District, acting or failing to act within the scope, course, and authority of her employment and her
employer.
18. At all material times, Defendant Public Safety Officer WILLIE ROGERS, (“Rogers”) in his
official and individual capacities, worked within Ingham County, State of Michigan.
19. At all material times, Rogers was an agent and/or employee of Defendant School District,
acting or failing to act within the scope, course, and authority of his employment and his employer.
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20. At all material times, Plaintiff’s attacker, “John Roe,” is and continues to be a student
attending the Defendant School District.2
III. APPLICABLE LAW AND POLICY
21. Title IX of the Education Amendments of 1972 (“Title IX), 20 U.S.C. § 1681(a) states that:
No person in the United States shall, on the basis of sex, be excluded from
participation in, be denied the benefit of, or be subjected to discrimination under
any education program or activity receiving Federal financial assistance…
22. Title IX is implemented through the Code of Federal Regulations. See 34 C.F.R. Part 106.
23. 34 C.F.R. § 106.8(b) provides:
…A recipient shall adopt and publish grievance procedures providing for prompt
and equitable resolution of student and employee complaints alleging any action
which would be prohibited by this part.
24. In Gebser v. Lago Vista Independent School District, 524 U.S. 274 (1988), the United States
Supreme Court recognized that a recipient of federal educational funds intentionally violates Title IX, and
is subject to a private damages action, where the recipient is “deliberately indifferent” to known acts of
teacher-student discrimination.
25. In Davis v. Monroe County Board of Education, 526 U.S. 629 (1999), the United States
Supreme Court extended the private damages action recognized in Gebser to cases where the harasser is a
student, rather than a teacher.
26. Davis held that a complainant may prevail in a private Title IX damages action against a
school district in cases of student-on-student harassment where the funding recipient is:
a) deliberately indifferent to sexual harassment of which the recipient has
actual knowledge, and
b) the harassment is so severe, pervasive, and objectively offensive that it
can be said to deprive the victims of access to the educational opportunities or benefits
provided by the school.
Davis, 526 U.S. at 1669-76.

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John Roe is a minor and will not be identified to protect his identity.

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27. The Fourteenth Amendment to the United States Constitution provides in pertinent part that
no State shall “deny to any person within its jurisdiction the equal protection of the laws.” U.S. Const.
amend. XIV, § 1.
28. At MCL 380.1311(2) Michigan law provides that “If a pupil…commits criminal sexual
conduct in a school building or on school grounds, the school board, or the designee of the school
board…shall expel the pupil from the school district permanently.”
29. The Lansing School District’s Code of Conduct provides disciplinary action in the event of
Sexual Harassment or intimidation. That policy defines sexual harassment to include “Unwelcome sexual
advances, teasing, jokes, remarks, or questions, either verbal or physical, toward another person because
of his/her sex or sexual orientation. Also includes a request for sexual favors or other verbal or physical
conduct of a sexual nature where such conduct has the purpose or effect of unreasonably interfering with
a student’s educational performance by creating an intimidating, hostile or offensive educational
environment.” (See Code of Conduct page 17 attached as Exhibit 1.)
IV. COMMON ALLEGATIONS
30. At all material times, the School District was receiving federal funding, as contemplated by
Title IX, 20 U.S.C. § 1681, et seq.
31. The School District implemented and executed policies and customs in regard to the events
that resulted in the deprivation of Plaintiff’s constitutional, statutory, and common-law rights.
32. The School District is responsible for ensuring that all its employees are properly trained and
supervised to perform their jobs.
33. The School District is responsible for the acts and omissions of its employees.
34. At the time of the attack that gave rise to the events complained of herein, Plaintiff was a 14year-old ninth grader at Eastern High School (“Eastern”).
35. At the time of the attack that gave rise to this action, student John Roe (“John Roe”) was also
a 14-year-old ninth grader at Eastern.

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36. John Roe is diagnosed with an ADHD impulsivity disorder, is classified as “otherwise health
impaired” (OHI), and is under treatment for this disorder. (See Motion attached as Exhibit 2.)
37. On October 13, 2015 at approximately 2:00 p.m., John Roe violently and forcibly sexually
assaulted Plaintiff in a stairwell in Eastern. (“Assault”).
38. On more than one occasion before the assault, Plaintiff witnessed John Roe exhibit violent
and impulsive behavior giving Plaintiff a reasonable fear that John Roe was capable of harming her.
39. Plaintiff did not report the assault to any authority figures in the School District as she was
afraid she would get into trouble.
40. The School District’s written Student Code of Conduct provides the following definition for
Obscene and Lewd Behavior under Behaviors Which May Lead to Disciplinary Action: “Obscene or
Lewd Behavior – The act of using obscene or profane language in verbal or written form,
possessing pornographic pictures, performing offensive gestures or acts or engaging in conduct of a
sexual nature regardless of consent.” Emphasis added. (See Code of Conduct page 17 attached as
Exhibit 1.)
41. On October 14, 2015, John Roe himself reported the sexual assault to Officer Rogers.
42. John Roe told Officer Rogers that Plaintiff’s boyfriend was threatening John Roe and that
John Roe was in fear of being beat up.
43. Officer Rogers called Plaintiff out of class, took Plaintiff to a school office, and asked
Plaintiff for her version of the events that had taken place the previous day.
44. Plaintiff gave Officer Rogers her statement. She explained that John Roe had taken her into
the stairwell, took his penis out of his pants, masturbated himself, forced her to rub his penis, and
attempted to force his penis into her mouth, all of which was without her consent.
45. Officer Rogers told Plaintiff that he was going to find the closed-circuit security footage from
the stairwell security camera and watch the incident to see if what Plaintiff reported in her statement
matched what was in the footage.

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46. AP Stevens and Officer Rogers later told Plaintiff that Officer Rogers and AP Stevens had
watched the video footage of the incident.
47. Officer Rogers told Plaintiff that what Officer Rogers and AP Stevens saw in the video did
not match what Plaintiff said in her statement, giving Plaintiff the impression that they did not believe
her. Officer Rogers then asked Plaintiff did she want to “change anything” about what she said in her
statement. Plaintiff steadfastly maintained that her statement was accurate and that she did not want to
change anything.
48. Officer Rogers then told Plaintiff that she was being suspended for Lewd and Lascivious
behavior pursuant to the Lansing School District Student Code of Conduct for engaging in sexual activity
during school.
49. Officer Rogers contacted Plaintiff’s mother L. Doe,3 told her mother Plaintiff had been an
“active participant in sexual activity in the Jerome/Penn stairwell” with John Roe during school hours,
and that Plaintiff needed to be picked up from school. (See Disciplinary Form attached as Exhibit 3).
50. Plaintiff was suspended for what was supposed to be a ten-day suspension beginning on
October 14, 2015, with a return date of October 27, 2015. (Exhibit 3).
51. On October 14, 2015, Plaintiff’s mother C. Doe contacted the school to discuss Plaintiff’s
return to school. Plaintiff’s parents were concerned that Plaintiff was suspended for being an “active
participant” when she was the victim of a traumatizing sexual assault.
52. On October 14, 2015, C. Doe attempted to report the assault herself to the Lansing Police
Department because to the best of her knowledge, the assault has not been reported by school personnel.
53. Despite repeated messages left with Pohl’s office and Canul’s office, no calls were ever
returned to Plaintiff’s mother C. Doe.
54. A police report was eventually filed with the Lansing Police Department by C. Doe on her
own volition.

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Plaintiff’s parents are both female, referred to as L. Doe and C. Doe.

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55. A meeting was scheduled with Student Services Specialist McWilliams to be held on October
22, 2015, for Plaintiff and her parents, C. Doe and L. Doe, and Stevens.
56. During this meeting, McWilliams told Plaintiff and her parents the following:
a) That McWilliams reviewed the video and found that Plaintiff
had not consented to the sexual activity, and;
b) That although Plaintiff had not consented to the sexual activity, she did
not have a “strong enough no,” she did not “try to get away,” and she did
“not fight back” and;
c) Plaintiff could not return to school on Tuesday, October 27, 2015 as stated
in the original suspension notice. (Exhibit 3.)
57. Plaintiff responded to these comments by asking McWilliams “What did you expect me to do,
hit him?”
58. McWilliams responded to Plaintiff’s question with the following statement, “No, you should
not have hit him, but you could have said to him, ‘is that all you’ve got?’”
59. Present during this meeting was Stevens, who McWilliams confirmed this statement with by
saying in front of Plaintiff, “Isn’t that right Mr. Stevens, wouldn’t that deflate a guy if you said that to
him?”
60. Once these comments were made, C. Doe and L. Doe immediately took their Plaintiff
daughter and left the meeting.
61. During the October 22, 2015 meeting, McWilliams told C. Doe and L. Doe she would call
them on Monday, October 26, 2015 to inform them as to when Plaintiff could return to school. No call
was received on October 26, 2015.
62. On October 27, 2015 McWilliams called C. Doe and told her that Plaintiff could not return to
school until a plan could be put into place to “curb [Plaintiff’s] behavior.”
63. On October 28, 2015 at 3:00 pm, McWilliams called C. Doe and told C. Doe that Plaintiff
could not come back to school until the following Monday, November 2, 2015.
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64. On October 28, 2015 at 3:35 pm, Susan Lands, McWilliam’s Supervisor, called C. Doe and
told C. Doe that Plaintiff could return to school the following day, October 29, 2015.
65. Plaintiff returned to school on October 29, 2015. John Roe, who was also suspended,
returned to school but was transferred to Lansing Everett, another school in the district.
66. On November 2, 2015, a representative from the Superintendent’s office called C. Doe to
schedule what was termed as an “apology meeting” for November 9, 2015. This meeting was
rescheduled for November 23, 2015.
67. At the November 23, 2015 meeting, Canul had no idea what the meeting was about, and had
no concept that it was intended to be an “apology” to the Doe family.
68. Despite the findings of Officer Rogers and Stevens that Plaintiff was an active participant in a
sexual activity, the Lansing Police Department found otherwise, and they also found that the video
supported “a majority” of Plaintiff’s claims. (See Lansing Police Department Report page 4 attached as
Exhibit 4.)
69. John Roe was charged with four felonies: #1 Criminal Sexual Conduct-Assault with Intent to
Commit Sexual Penetration, #2 Gross Indecency between Male and Female-Committing/Procuring, #3
Criminal Sexual Conduct- 4th Degree, and #4 Indecent Exposure. John Roe pled to one count of Indecent
Exposure with the agreement of Plaintiff and her parents. (See Prosecutor’s Charging Document Attached
as Exhibit 5.)
70. After Plaintiff returned to school, she was bullied, teased, and harassed by other students for
being “boy crazy.”
71. Plaintiff was suspended to student services again on December 1st, 2015 for a separate
incident, and met with student services on January 4, 2016 regarding this second suspension.
72. That meeting was attended by Susan Land, McWilliams, Pohl, Plaintiff and her parents,
Plaintiff’s counsel Karen Truszkowski, and the attorney for the School District, Barbara Ruga, who
attended remotely.

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73. At that meeting, options for Plaintiff’s return to school were discussed. Plaintiff was not
given the option of returning to Eastern. Plaintiff could not attend Everett as John Roe was transferred
there leaving Sexton High School as the only remaining option.
74. Plaintiff was not comfortable attending Sexton since Stevens was now the Principal at Sexton
so Plaintiff was given the option of online classes using APEX, an online class system.
75. Assurances were made that if Plaintiff chose this online option, she would be provided with
all the necessary technology, support, and equipment necessary to complete her schoolwork online at
home, and that a Chromebook would be given to her with internet restrictions allowing her to access only
school-related internet websites.
76. Plaintiff was not provided with any initial instruction on using the APEX system, was not
provided with the necessary math calculator until several months into the semester, and was told she
would have to come into one of the schools to charge the calculator as she would not be provided with a
charger.
77. Although Plaintiff was assured by the School District that a printer would be provided for her
to complete her school work, she has been told that she has to come in to one of the schools to print her
work.
78. Plaintiff does not always have transportation available to her making printing difficult.
79. Plaintiff was also assured that she would be allowed to continue to participate in after-school,
extra-curricular activities, specifically the Native American Youth Association (“NAYA”), whose
meetings were held at Eastern.
80. Beginning in January 2016, Plaintiff began attending the NAYA meetings at Eastern. On
March 8, 2016, Rogers approached Plaintiff when she was waiting in the Welcome Center of Eastern for
a NAYA meeting to begin, told Plaintiff she was “trespassing” and physically escorted her out of the
building, subjecting Plaintiff to humiliation and embarrassment.
81. Plaintiff has lost the opportunity to participate in extra-curricular activities such as soccer,
and she has become socially isolated from her peers, teachers, and friends.
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82. Plaintiff’s sex-based harassment has resulted in her being denied the educational benefits of
her school and the school district.
83. Plaintiff suffered sex-based harassment that was severe, pervasive, and objectively offensive.
84. The School District’s response and its officials’ conduct was such that future reasonable
students in Plaintiff’s circumstances would be chilled from reporting sexual harassment and/or assault.
85. As a direct and proximate result of the harassing educational environment created by
Defendants’ deliberately indifferent response to the sexual assault and subsequent harassment, as well as
violations of her Fourteenth Amendment Rights, Plaintiff has suffered and continues to suffer
psychological damage, emotional distress, loss of standing in her community, and damage to her
reputation, and her future relationships have been negatively affected.
86. Plaintiff has required ongoing counseling and elevated levels of medication to address her
depression and anxiety caused by Defendants’ conduct and the resulting harassing educational
environment.
87. Plaintiff has also been deprived of a normal childhood education due to Defendants’ conduct
and the resulting educational environment.
88. Plaintiff has also been damaged by missed educational opportunities and her future earning
capabilities have been damaged by Defendants’ conduct and the resulting hostile educational
environment.
COUNT I
VIOLATION OF TITLE IX
AS TO DEFENDANT LANSING SCHOOL DISTRICT
(20 U.S.C. § 1681 et seq)
(The School’s Deliberate Indifference to Alleged Sexual Harassment)
Paragraphs 1 through 88 are incorporated by reference as if stated in full herein.
89. The sex-based harassment articulated in the Plaintiff’s General Allegations was so severe,
pervasive, and objectively offensive that it deprived Plaintiff of access to educational opportunities or
benefits provided by the school.
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90. The Defendant School District created and/or subjected Plaintiff to a hostile educational
environment in violation of Title IX of the Education Amendments of 1972, 20 U.S.C. § 1681 (a) (“Title
IX”), because
a) Plaintiff was a member of a protected class;
b) she was subjected to sexual harassment in the form of a sexual assault by another student;
c) she was subjected to harassment based on her sex; and
d) she was subjected to a hostile educational environment created by the School District’s lack of
and/or improper policies and procedures and the failure to properly investigate and/or address the
sexual assault and subsequent harassment.
91. Defendant School District and its officials had actual knowledge of the sexual assault and
the resulting harassment of Plaintiff created by its policy to suspend any student involved in sexual
activity on school grounds, Regardless of Consent.
92. The Defendant School District’s failure to appropriately respond to the alleged sexual
harassment, resulted in Plaintiff, on the basis of her sex, being excluded from participation in, being
denied the benefits of, and being subjected to discrimination in the School District’s education program in
violation of Title IX.
93. Defendant School District’s policy to immediately suspend any student involved in sexual
activity on school grounds, regardless of consent, resulted in acting with deliberate indifference toward
Plaintiff, and this policy has a chilling effect upon any student who has been the victim of an assault from
reporting the assault for fear of being punished.
94. Defendant School District persisted in its actions and inaction even after it had actual
knowledge of the harm suffered by Plaintiff.
95. Defendant School District engaged in a pattern and practice of behavior designed to
discourage and dissuade students and parents of students who had been sexually assaulted from seeking
prosecution and protection and from seeking to have sexual assaults from being fully investigated.

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96. This policy and/or practice constituted disparate treatment of females and had a disparate
impact on female students.
97. Plaintiff has suffered emotional distress and psychological damage, and her character and
standing in the community have suffered from the harassment fostered as a direct and proximate result of
Defendant School District’s deliberate indifference to her rights under Title IX.
COUNT II
1983 VIOLATION AS TO
DEFENDANTS LANSING SCHOOL DISTRICT,
CANUL, POHL, STEVENS, ROGERS, AND WILLIAMS
(42 U.S.C. § 1983)
Paragraphs 1 through 97 are hereby incorporated by reference as if set forth in full herein.
98. Under the Fourteenth Amendment, Plaintiff had the right as a public school student to
personal security and bodily integrity and Equal Protection of Laws.
99. Defendants Canul, Pohl, Stevens, Rogers, and Williams were all state actors acting under the
color of state law.
100. Defendants each subjected Plaintiff to violations of her right to personal security and bodily
integrity and Equal Protection of Laws by: failing to monitor the closed-circuit camera feeds displaying
real-time activity throughout the school, suspending the Plaintiff for being the victim of a sexual assault,
failing to adequately train and supervise Pohl, Stevens, Rogers, and Williams, and manifesting deliberate
indifference to the sexual assault and ongoing harassment of Plaintiff by other students.
101. The School District has and/or had unconstitutional customs or policies of
a) failing to investigate evidence of criminal or tortious misconduct against School
District students in the nature of violations of their right to personal security and
b) failing to adequately train and supervise School District employees with regard to
maintaining, preserving and protecting students from violations of their right to personal
security, bodily integrity, and Equal Protection of Laws.

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102. On information and belief, the School District has followed these unconstitutional customs
and policies not only with regard to Plaintiff but also with regard to criminal and tortious misconduct
committed against other School District students.
103. The School District’s policies and/or practices constituted disparate treatment of females
and had a disparate impact on female students.
104. Defendants Canul, Pohl, Stevens, Rogers, and Williams are or were at the time of events
complained of within, policymakers for the purpose of implementing the School District’s
unconstitutional policies or customs.
105. Plaintiff has suffered emotional distress and psychological damage, and her character and
standing in her community have suffered from the harassment fostered as a direct and proximate result of
Defendant School District’s deliberate indifference to her rights under the Fourteenth Amendment.
COUNT IV
MONELL LIABILITY FOR FAILURE TO TRAIN AND SUPERVISE
AS TO RESPONSE TO SEXUAL ASSAULT
AS TO DEFENDANT LANSING SCHOOL DISTRICT
(42 U.S.C. § 1983)
Paragraphs 1 through 105 are hereby incorporated by reference as if set forth in full herein.
106. Defendants Canul, Pohl, Stevens, Rogers, and Williams were “state actors” working for the
Lansing School District, a federally funded school system.
107. Defendants Canul, Pohl, Stevens, Rogers, and Williams acted under color of “state law”
when they responded inadequately and inappropriately to Plaintiff’s sexual assault.
108. Defendants Canul, Pohl, Stevens, Rogers, and Williams failed to preserve Plaintiff’s
constitutional right to equal protection as guaranteed by the Fourteenth Amendment.
109. Under the Equal Protection Clause of the Fourteenth Amendment, Plaintiff had the right to
equal access to an educational environment free from harassment and discrimination.

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110. Defendants Canul, Pohl, Stevens, Rogers, and Williams should have known that their
response to sexual assault allegations must comply with federal law, particularly as outlined in Title IX’s
published and widely promulgated implementing regulations.
111. Defendants Canul, Pohl, Stevens, Rogers, and Williams each violated Plaintiff’s right to
equal access by:
a) failing to take immediate and appropriate action to investigate or otherwise determine what
occurred once informed of possible sexual violence;
b) failing to take prompt and effective steps to prevent and end the sexual violence, prevent its
recurrence, and address its effects, whether or not the sexual violence is the subject of a
criminal investigation;
c) failing to take steps to protect the Plaintiff and other students as necessary;
d) failing to provide a grievance procedure for students to file complaints of sexual
discrimination, including complaints of sexual violence;
e) failing to use a preponderance of evidence standard to resolve complaints of sex
discrimination in grievance procedures;
f) failing to notify parties of the outcomes of complaints;
g) failing to enact adequate safety procedures including, but not limited to, monitoring the realtime camera feeds from closed-circuit cameras placed throughout the school.
112. Defendant Lansing School District violated Plaintiff’s Fourteenth Amendment right to equal
protection by failing to properly train and supervise its employees as to these mandated investigative
requirements.
113. Defendants have acknowledged that despite the presence of closed-circuit cameras
throughout the school with real-time feeds, the camera monitors are not always watched by school
personnel.
113. These policies and/or practices constituted disparate treatment of females and had a
disparate impact on female students.
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114. Defendants’ actions and lack of actions were the proximate cause of Plaintiff’s emotional
distress and psychological damage, and her character and standing in her community have suffered from
the harassment fostered as a result of Defendant School District’s deliberate indifference to her right to
equal protection under the Fourteenth Amendment.
WHEREFORE, Plaintiff respectfully requests judgment in her favor and against Defendants
Lansing School District, Canul, Pohl, Stevens, Rogers, and Williams as follows:
A. Compensatory damages for Plaintiff’s psychological and emotional distress and damages,
loss of standing in her community, damage to her reputation, and her family’s unreimbursed
out-of-pocket expenses incurred in response to these circumstances;
B. Punitive damages;
C. Injunctive relief requiring Defendant School District to take effective steps to prevent sexbased discrimination and harassment, including sexual assault, in its education programs,
fully investigate conduct that may constitute sex-based harassment and/or sexual assault;
comply with the requirements of Title IX, amend its Student Conduct Code, and mitigate the
effects of harassment and/or assault including by eliminating any hostile environment that
may arise from or contribute to it.
D. Statutory Interest;
E. Costs; and
F. Reasonable attorney fees

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JURY DEMAND
Now comes Plaintiff, Jane Doe, by and through her attorney, Karen Truszkowski, and demands a
trial by jury.
Dated: June 6, 2016

/s/Karen Truszkowski
Karen Truskowski (P56929)
Temperance Legal Group PLLC
530 Mall Court #131
Lansing, MI 48912
517.235.3053 phone / 347.412.6081 fax
Attorney for Plaintiff

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