The following excerpt is from Roe ex rel. Callahan v. GUSTINE UNIFIED SCHOOL, 678 F. Supp.2d 1008 (E.D. Cal. 2009):
Case law does not expressly limit the employee who may trigger a school district's liability under Title IX; it is an "open question." See, e.g., Hawkins v. Sarasota
[678 F. Supp.2d 1034]
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