IN THE CIRCUIT COURT OF CEDAR COUNTY, MISSOURI JANE DOE I, Plaintiff, v. CIRCLE OF HOPE GIRLS RANCH AND BOARDING SCHOOLS, Serve: Registered Agent – Boyd Householder 20285 E. Highway N Humansville, MO, 65674 and BOYD HOUSEHOLDER, Serve: 20285 E. Highway N Humansville, MO, 65674 and STEPHANIE HOUSEHOLDER, Serve: 20285 E. Highway N Humansville, MO, 65674 Defendants. ) ) ) ) ) ) Case No. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) PETITION Jane Doe I, plaintiff, by and through counsel, Haden, Cowherd & Bullock, L.L.C., for her Petition against Circle of Hope Girls Ranch and Boarding Schools (“Circle of Hope”), Boyd Householder and Stephanie Householder, defendants, states and avers as follows: PARTIES, JURISDICTION AND VENUE 1. Plaintiff Jane Doe I (hereinafter “Plaintiff”) is an individual currently residing in the State of Texas. Electronically Filed - Cedar - September 23, 2020 - 03:23 PM 20CD-CV00406 Defendant Circle of Hope is a Missouri not-for-profit corporation having its principal place of business in Cedar County, Missouri. 3. Defendant Boyd Householder is an individual residing in Cedar County, Missouri. As an administrator of Circle of Hope, Defendant Boyd Householder acted within the scope and course of his employment by Circle of Hope at all relevant times. 4. Defendant Stephanie Householder is an individual residing in Cedar County, Missouri. As an administrator of Circle of Hope, Defendant Stephanie Householder acted within the scope and course of her employment by Circle of Hope at all relevant times. 5. The events at issue in this Petition occurred in Cedar County, Missouri. 6. Jurisdiction and venue are proper in this Court. GENERAL ALLEGATIONS 7. Defendant Circle of Hope assumes custodial care for girls of a range of ages and provides facilities for such services. Circle of Hope does not receive State or Federal resident placements nor public monies or assistance for its services in housing and having custody of such residents. By accepting custodial care of its residents, Circle of Hope and its agents and administrators owed its residents, including Jane Doe I, the duty to prevent harm and to protect them from all forms of abuse. 8. At all relevant times, Defendant Circle of Hope acted through its agents and employees and is vicariously liable for the actions and omissions of its agents and its employees, including Defendants Boyd and Stephanie Householder. 9. At all relevant times, Circle of Hope administrators Boyd Householder and Stephanie Householder lacked the minimum education and training requirements as Electronically Filed - Cedar - September 23, 2020 - 03:23 PM 2. and were unqualified to act as the administrators of Circle of Hope. 10. Defendants Boyd Householder and Stephanie Householder did not have any training, degrees, or experience in child or adolescent care, psychiatry, welfare, child or adolescent development, child or adolescent safety, child or adolescent security, child or adolescent discipline or any other related field, and were not qualified to operate a residential placement facility for young girls. 11. Jane Doe I was a resident of Circle of Hope from approximately December 8, 2014 through February 14, 2015. Circle of Hope was contracted by the parent of Jane Doe I to provide, and was obligated to provide for the care, custody, supervision, and safety of Jane Doe I while a resident of Circle of Hope. 12. Jane Doe I arrived at Circle of Hope when she was sixteen (16) years old. 13. Jane Doe I’s family located Circle of Hope through her church pastor. 14. Jane Doe I’s church pastor drove her from Texas to Missouri and delivered her into the custody, control and supervision of Defendants. 15. While a resident of Circle of Hope, Jane Doe I was physically abused by Defendants and was sexually abused, assaulted, molested, and raped by the son of Boyd and Stephanie Householder (the “Householder son”). 16. From its creation in 2006 through the time that Jane Doe I arrived at Circle of Hope in December, 2014, there were numerous prior acts of severe abuse by Defendants and/or sexual assault and/or rape perpetrated on the premises of Circle of Hope by administrator Boyd Householder and the Householder son. Electronically Filed - Cedar - September 23, 2020 - 03:23 PM exemplified by regulations promulgated by the Missouri Department of Social Services In addition, in or about 2009, a male employee of Circle of Hope was arrested for sexually abusing minor residents of Circle of Hope. Despite their knowledge of prior sexual abuse, Defendants took no corrective action to ensure such activity would not continue and failed to change its policies or implement reasonable safeguards to protect residents of Circle of Hope. 18. During the period of time described above, Defendant Circle of Hope, through its employees, including Defendants Boyd and Stephanie Householder, was aware of multiple and continuing instances of physical and sexual assaults of minor residents of Circle of Hope, but took no reasonable actions to stop the ongoing abuse and assaults or otherwise implement safeguards to protects residents at Circle of Hope, including the Plaintiff. 19. During the time period described above, the Board of Directors of Circle of Hope, knew or had reason to know about the ongoing physical and sexual assault occurring at Circle of Hope, but took no reasonable actions to stop the ongoing abuse and assaults or otherwise implement safeguards to protect residents at Circle of Hope, including Plaintiff. 20. Despite knowing otherwise, Defendants represented to parents considering placing their daughters’ at Circle of Hope that measures were in place to provide for their safety and assured that their daughters would be provided with counseling and treatment for the issues that led them to Circle of Hope. 21. In fact, no employees of Circle of Hope, including Defendants Boyd and Stephanie Householder, had qualifications to provide counseling or treatment and the program was in fact designed through systematic abuse to emotionally and physically break the residents rather than provide effective evidence based treatments. Electronically Filed - Cedar - September 23, 2020 - 03:23 PM 17. As a so called religious based organization, Circle of Hope was permitted to forgo State licensure and was at all times completely unregulated by Federal, State, or local agencies and such lack of regulation permitted the Defendants to implement their abusive program without oversight. 23. Circle of Hope’s “treatment” program consisted of an abusive and strictly regimented bootcamp environment where every detail of the residents’ lives were monitored, manipulated, and controlled. The abusive policies and procedures at Circle of Hope, which were designed to physically and psychologically intimidate, terrorize, and ultimately mentally break the residents, included (but were by no means limited to) the following: a. Preventing residents (many of whom are at Circle of Hope for years) from speaking to one another except in strictly regulated group environments in order to maintain a culture of obedience, fear, and silence with regard to the ongoing abuse; b. Assigning staff and/or senior residents to monitor and view all aspects of daily life at all times, including such private activities as showering and using the restroom; c. Routinely physically assaulting and manhandling residents by throwing them against walls, throwing them to the ground, striking and slapping them, and performing unnecessary “restraints.” d. Performing “restraints” which involved 4 or more people holding the limbs of the restrained individual and pressing on pressure points on the body. This practice often caused pain and numbness for days afterward and was Electronically Filed - Cedar - September 23, 2020 - 03:23 PM 22. control over residents who were a danger to themselves or others; e. Arbitrary determinations that girls were either “overweight” or “underweight” and giving them half rations of food or forcing them to eat double or triple rations to correct their “weight issues;” f. For residents that did not finish their meals, force feeding them until they vomited; g. Rather than providing daily schooling (Circle of Hope does not employ qualified educators and very rarely attempts to provide schooling to residents), forcing residents to perform constant unpaid manual labor on the farm at Circle of Hope; h. Providing only limited water breaks during work hours and often refusing to provide water at all even during hot summer days; i. For residents that requested water while working, forcing them to drink copious amounts until they became sick; j. Often refusing to allow restroom breaks to the residents and if accidents occurred as a result, forcing them to continue working for the rest of the day in wet or soiled clothing; k. Refusing to provide medical treatment for numerous serious injuries and infections that occurred to residents; l. Forcing residents to stand with their nose against a wall for days and weeks at a time with minimal restroom breaks and no opportunity to sit down or rest their legs; Electronically Filed - Cedar - September 23, 2020 - 03:23 PM designed and intended to maximize pain and suffering rather than to gain In winter months, forcing girls to remove their clothing and go outside into the cold for extended periods of time wearing nothing but their slips; n. Forcing girls to remain in pushup position for hours at a time and performing arbitrary “restraints” following their physical inability to remain in position; o. Forcing residents into solitary confinement in complete darkness for days at a time. 24. The Householder son, aged fifteen (15) or sixteen (16) years old at the time at issue, resided on the premises of Circle of Hope and was allowed to have absolute supervisory authority over the female residents of Circle of Hope. 25. Soon after her arrival at Circle of Hope, the Householder son took a special interest in Jane Doe I. 26. The Householder son began to frequently follow Jane Doe I. He would sit close beside her, press up against her, place his hand on her leg, or brush up against her breasts or buttocks. These events occurred when Defendants Boyd and Stephanie Householder were in the same room and within their eyesight. 27. The Householder son, who was at or near the same age as the girls he was assigned to supervise, was permitted to select girls for outdoor work duties which occurred outside of the direct supervision of Defendants Boyd and Stephanie Householder. This was permitted despite numerous prior reports over several years to Defendants Boyd and Stephanie Householder that their son had previously sexually assaulted residents of Circle of Hope when left unsupervised. The Householder son frequently chose Jane Doe I to be a part of the group performing outdoor work duties under his supervision. Electronically Filed - Cedar - September 23, 2020 - 03:23 PM m. In mid to late December, 2014, while on an outdoor work duty supervised by the Householder son, he separated Jane Doe I from the rest of the group of girls and sent her into an unoccupied house on the Circle of Hope property where she was told to sweep the floor. 29. A short time later, the Householder son entered the house, and without warning, he physically attacked Jane Doe I and threw her against a wall. He continued the physical attack during which he removed Janie Doe I’s clothing and forcibly raped her. 30. After the completion of the rape, the Householder son told Jane Doe I to put her clothes back on and go back to work with the other girls. Jane Doe I was warned not to tell anyone what had occurred. 31. In January or February 2015, the Householder son committed similar acts of sexual assault against Jane Doe I. 32. In addition to numerous other acts of physical abuse in the manner of the abuses described above, in January or February, 2015, Jane Doe I was physically attacked by Defendant Boyd Householder, thrown into a wall, and violently thrown to the ground. She was also arbitrarily restrained for over an hour while staff pressed on her pressure points. 33. On another occasion, Defendant Boyd Householder ordered his German Shepard dog to attack Jane Doe I. The dog latched on to Jane Doe I’s leg until told to release by Defendant. 34. Following the attack, Jane Doe I was forced to sign an accident report stating that the dog bit her on accident. Electronically Filed - Cedar - September 23, 2020 - 03:23 PM 28. Soon after, Plaintiff was forced to undress until she was wearing nothing except a dress slip and was forced outside for several hours at night to perform manual labor in freezing temperatures. 36. Due to Defendant’s policy of starving residents that they felt were overweight, Jane Doe I lost more than forty (40) pounds in the two (2) months that she was at Circle of Hope before she was removed from the camp by her mother. COUNT I Jane Doe I, for Count I of plaintiff’s Petition against Circle of Hope, states and alleges as follows: 1. Plaintiff incorporates herein by reference all allegations set forth in the General Allegations. 2. Defendant Circle of Hope. and its employees and agents, were negligent and breached their duty of care to Plaintiff in one or more of the following respects: a. They hired, retained, and failed to supervise Defendants Boyd Householder and Stephanie Householder despite their complete lack of qualifications to be administrators of a residential youth facility; b. They failed to adequately and properly supervise, monitor and maintain control over residents and other juveniles at Circle of Hope, including Plaintiff, so as to prevent the harms to Jane Doe I set forth herein; c. They failed to have in place appropriate policies and procedure for the monitoring and supervising of residents and other juveniles at Circle of Hope so as to prevent the harms to Jane Doe I set forth herein; Electronically Filed - Cedar - September 23, 2020 - 03:23 PM 35. They implemented and maintained policies and procedures which permitted a program that was and is abusive as set forth herein; e. They failed to have in place adequate monitoring equipment and facilities for supervising and controlling juveniles at Circle of Hope, including Plaintiff, so as to prevent instances of physical and sexual abuse, sexual molestation, sexual assaults, and/or physical assault; f. They permitted and failed to correct a culture and custom at Circle of Hope which ignored sexual assault of residents by employees and family members of employees; g. They failed to take reasonable steps to prevent Jane Doe I from being physically and sexually abused, molested and/or assaulted by other juveniles at Circle of Hope; h. They placed known sexual predators in supervisory roles over residents, including Jane Doe I. i. They placed known sexual predators in supervisory roles over residents when their facility was known to be inadequately equipped and/or inadequately staffed to properly supervise, monitor and control such individuals and to provide a safe environment to Jane Doe I; j. They knew or had reason to know that Circle of Hope through its facilities, staff, residents, policies and/or practices, presented a risk of harm to Jane Doe I of physical and sexual abuse, sexual molestation, sexual assault, and/or physical assault, but failed to take reasonable steps so as to reduce or eliminate such risk of harm; Electronically Filed - Cedar - September 23, 2020 - 03:23 PM d. They failed to train their employees and staff members to recognize and respond to dangers and prevent threats or acts of sexual abuse and assault and failed to have in place appropriate policies and procedures requiring such training; l. They failed to train their employees to adequately supervise residents and other juveniles at Circle of Hope, including Jane Doe I, in order to prevent acts of sexual abuse and assault and failed to have in place appropriate policies and procedures requiring such training; m. They failed to have in place appropriate policies and procedures requiring the separation of Plaintiff from the perpetrator of sexual abuse; n. Pleading in the alternative, they negligently hired, retained, trained and supervised the Householder son despite knowledge of his proclivity to commit sexual abuse. o. They failed to permit and failed to have in place policies permitting residents of Circle of Hope, including Jane Doe II, to report acts of abuse to outside entities and individuals, including parents. 3. As a direct and proximate result of the aforementioned negligent acts, or any one of them, Jane Doe I was physically and sexually abused, sexually molested, sexually assaulted, raped and/or physically assaulted at Circle of Hope. 4. Jane Doe I suffered physical injuries, emotional distress and psychological injuries as a result of the abuses suffered while a resident of Circle of Hope that have necessitated medical and psychological care and treatment. Electronically Filed - Cedar - September 23, 2020 - 03:23 PM k. As a direct and proximate result of the aforementioned negligent acts of the defendant, Jane Doe I suffered permanent and ongoing emotional and psychological trauma that was and is both medically significant and diagnosable. WHEREFORE, Jane Doe I, Plaintiff, prays for judgment upon Count I against Circle of Hope, for damages in a fair and reasonable amount determined by the jury, for the costs herein expended and for such other and further relief as the Court deems appropriate. COUNT II Jane Doe I for Count II of plaintiff’s Petition against Circle of Hope, states and alleges as follows: 1. Plaintiff incorporates herein by reference all allegations contained in the General Allegations and in Count I. 2. The negligence of Defendant as described in paragraph 2 of Count I and in repeatedly punishing Jane Doe I despite ongoing physical and sexual abuse involved an unreasonable risk of causing emotional distress to Jane Doe I. 3. Defendant knew or by using ordinary care could have known of such risks. 4. As a direct and proximate result of such negligence, Jane Doe I sustained medically diagnosable and significant emotional distress. WHEREFORE, Jane Doe I, Plaintiff, prays for judgment upon Count II against Circle of Hope, for damages in a fair and reasonable amount determined by the jury, for the costs herein expended and for such other and further relief as the Court deems appropriate. COUNT III Electronically Filed - Cedar - September 23, 2020 - 03:23 PM 5. Householder and Stephanie Householder, states and alleges as follows: 1. Plaintiff incorporates herein by reference all allegations contained in the General Allegations and in Counts I and II. 2. Defendant Boyd and Stephanie Householder. and their employees and agents, were negligent and breached their duty of care to Plaintiff in one or more of the following respects: a. They failed to adequately and properly supervise, monitor and maintain control over residents and other juveniles at Circle of Hope, including Plaintiff, so as to prevent the harms to Jane Doe I set forth herein; b. They failed to have in place appropriate policies and procedure for the monitoring and supervising of residents and other juveniles at Circle of Hope so as to prevent the harms to Jane Doe I set forth herein; c. They created, implemented, and maintained policies and procedures which permitted a program that was and is abusive as set forth herein; d. They failed to have in place adequate monitoring equipment and facilities for supervising and controlling juveniles at Circle of Hope, including Plaintiff, so as to prevent instances of physical and sexual abuse, sexual molestation, sexual assaults, and/or physical assault; e. They permitted and failed to correct a culture and custom at Circle of Hope which ignored sexual assault of residents by employees and family members of employees; Electronically Filed - Cedar - September 23, 2020 - 03:23 PM Jane Doe I, for Count III of plaintiff’s Petition against Defendants Boyd They failed to take reasonable steps to prevent Jane Doe I from being physically and sexually abused, molested and/or assaulted by other juveniles at Circle of Hope; g. They placed known sexual predators in supervisory roles over residents, including Jane Doe I. h. They placed known sexual predators in supervisory roles over residents when their facility was known to be inadequately equipped and/or inadequately staffed to properly supervise, monitor and control such individuals and to provide a safe environment to Jane Doe I; i. They knew or had reason to know that Circle of Hope through its facilities, staff, residents, policies and/or practices, presented a risk of harm to Jane Doe I of physical and sexual abuse, sexual molestation, sexual assault, and/or physical assault, but failed to take reasonable steps so as to reduce or eliminate such risk of harm; j. They failed to train their employees and staff members to recognize and respond to dangers and prevent threats or acts of sexual abuse and assault and failed to have in place appropriate policies and procedures requiring such training; k. They failed to train their employees to adequately supervise residents and other juveniles at Circle of Hope, including Jane Doe I, in order to prevent acts of sexual abuse and assault and failed to have in place appropriate policies and procedures requiring such training; l. They failed to have in place appropriate policies and procedures requiring the separation of Plaintiff from the perpetrator of sexual abuse; Electronically Filed - Cedar - September 23, 2020 - 03:23 PM f. Pleading in the alternative, they negligently hired, retained, trained and supervised the Householder son despite knowledge of his proclivity to commit sexual abuse. o. They failed to permit and failed to have in place policies permitting residents of Circle of Hope, including Jane Doe II, to report acts of abuse to outside entities and individuals, including parents. 3. As a direct and proximate result of the aforementioned negligent acts, or any one of them, Jane Doe I was physically and sexually abused, sexually molested, sexually assaulted, raped and/or physically assaulted at Circle of Hope. 4. Jane Doe I suffered physical injuries, emotional distress and psychological injuries as a result of the abuses suffered while a resident of Circle of Hope that have necessitated medical and psychological care and treatment. 5. As a direct and proximate result of the aforementioned negligent acts of the Defendants, Jane Doe I suffered permanent and ongoing emotional and psychological trauma that was and is both medically significant and diagnosable. WHEREFORE, Jane Doe I, Plaintiff, prays for judgment upon Count III against Defendants Boyd and Stephanie Householder, for damages in a fair and reasonable amount determined by the jury, for the costs herein expended and for such other and further relief as the Court deems appropriate. COUNT IV Jane Doe I for Count IV of plaintiff’s Petition against Defendants Boyd Householder and Stephanie Householder, states and alleges as follows: Electronically Filed - Cedar - September 23, 2020 - 03:23 PM m. Plaintiff incorporates herein by reference all allegations contained in the General Allegations and in Counts, I, II and III. 2. The negligence of Defendant as described in paragraph 2 of Count III and in repeatedly punishing Jane Doe I despite ongoing physical and sexual abuse involved an unreasonable risk of causing emotional distress to Jane Doe I. 3. Defendant knew or by using ordinary care could have known of such risks. 4. As a direct and proximate result of such negligence, Jane Doe I sustained medically diagnosable and significant emotional distress. WHEREFORE, Jane Doe I, Plaintiff, prays for judgment upon Count IV against Defendants Boyd and Stephanie Householder, for damages in a fair and reasonable amount determined by the jury, for the costs herein expended and for such other and further relief as the Court deems appropriate. HADEN COWHERD & BULLOCK, L.L.C. By____/s/_Randy R. Cowherd_____________ Randy R. Cowherd #33796 Catherine A. Reade #53246 Philip R. Quinn #63180 2135 E. Sunshine, Suite 203 Springfield, MO 65804-1899 Phone: (417) 883-5535 Fax: (417) 883-5541 E-Mail: rcowherd@hcblawfirm.com pquinn@hcblawfirm.com Attorneys for Plaintiff Electronically Filed - Cedar - September 23, 2020 - 03:23 PM 1.