re required to carefully address of student-to-student sexual harassment and to take steps to remedy these problems when they arise (Yell & Katsiyannis, 2000).
In the case of Baynard v Alexandria City School Board, a Fourth Circuit of Appeals held that a school principal in Virginia was deliberately indifferent to a teacher's sexual abuse of a student and could be held liable for such abuse. In 1999, the Supreme Court had ruled in Gebser and Davis v Monroe County Board of Education (526 U.S. 629 [1999]) that schools and their principals can be held liable for severe and pervasive sexual harassment about which they were informed and failed to act upon (Sexual harassment casea, 2002).
The responsibility of principals in these instances is quite significant as it also is in cases involving freedom of expression. Stader (2001) reported that student rights to expression on school grounds were initially outlined in Tin
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