Ridge View High School Summons

ELECTRONICALLY FILED - 2022 Jan 25 4:11 PM - RICHLAND - COMMON PLEAS - CASE#2022CP4000425
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

) FIFTH JUDICIAL CIRCUIT
COUNTY OF RICHLAND )
)
Mother Doe, Individually, and as next ) CASE NO. 2022-CP-40-________
friend for John Doe (a minor child), )
)
Plaintiff, ) SUMMONS
) (Jury Trial Demand)
vs. )
)
Richland County School District Two,
Defendant.
TO THE DEFENDANT:
YOU ARE HEREBY SUMMONED and required to answer the Complaint in this
action of which a copy is hereby served upon you, and to serve a copy of your Answer to
the said Complaint on the subscriber at their offices, 1921 Henderson Street, Post Office
Box 532, Columbia, South Carolina 29202 within thirty (30) days after the service
thereof exclusive of the day of such service; and if you fail to answer the Complaint
within the time aforesaid, the Plaintiff in this action will apply to the Court for the relief
demanded in the Complaint and for a default judgment.
BAILEY LAW FIRM, L.L.C.
By: s/Tyler D. Bailey

Tyler D. Bailey
S.C. Bar No. 101915
1921 Henderson Street (29201)
P.O. Box 532
Columbia, SC (29202)
Telephone: 1-803-667-9716
Fax: 1-803-526-7642
Email: [email protected]
ATTORNEY FOR PLAINTIFFS
Columbia, South Carolina
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
) FIFTH JUDICIAL CIRCUIT
COUNTY OF RICHLAND )
)
Mother Doe, Individually, and as next ) CASE NO. 2022-CP-40-________
friend for John Doe. (a minor child), )
)
Plaintiff, ) COMPLAINT
) (Jury Trial Demand)
vs. )
)
Richland County School District Two,
Defendant.
PARTIES
The Plaintiffs, complaining of the Defendant Richland County School District Two
would respectfully show unto this Honorable Court:
Plaintiffs Mother Doe and John Doe
1. That Plaintiff Mother Doe (hereinafter “Mother Doe”), is and was a citizen
and resident of the County of Richland, State of South Carolina at all times relevant
herein.
2. That Plaintiff John Doe is the minor son of Plaintiff Mother Doe and is
and was a citizen and resident of the County of Richland, State of South Carolina at all
times relevant herein. That Plaintiff Mother Doe brings this action individually, and as
next friend for John Doe, her minor son (hereinafter Plaintiffs Mother Doe and John Doe
are collectively referred to as “Plaintiffs”).
3. That at all times relevant herein, Plaintiff John Doe was a minor student at
Ridgeview High School in Richland County School District Two and Defendant
Richland County School District Two owed a common law duty to protect the minor
child from harm, including abuse, hazing, assault, and sexual assault, while he was under
their care.
Defendant Richland County School District Two
4. That upon information and belief, the Defendant Richland County School
District Two is a school district operated as a subdivision of Richland County
Government and is a governmental agency with its principal place of business located in
the County of Richland, State of South Carolina and is responsible for the actions or
inactions of its agents, servants, contractors, volunteers, and employees.
5. That upon information and belief the majority, if not all, of the events to
this claim, took place at Ridgeview High School.
6. That Defendant Richland County School District Two is being sued in its
representative capacity pursuant to the South Carolina Tort Claims Act that makes the
employing entity liable for the torts of its employees and agents (S.C. Code §15-78-70).
Plaintiffs allege that Defendant Richland County School District Two is liable for the acts
and omissions of its employees, agents, servants, and contractors for the negligence,
gross negligence, recklessness, and other liability forming conduct, actions, and inactions
that caused the harm to Plaintiffs.
7. The negligent and grossly negligent acts, omissions, and liability forming
conduct, actions, and inactions of Defendant Richland County School District Two
include their agents, principals, employees and/or servants, both directly and vicariously,
pursuant to principles of non-delegable duty, apparent authority, agency, ostensible
agency and/or respondeat superior and the acts and/or omissions of the abovenamed
Defendant was the direct and proximate cause of the injuries, damages, and losses to
Plaintiffs.
JURISDICTION & VENUE
8. That this Court has jurisdiction over the subject matter of this litigation
and the parties heretofore named pursuant to Article V, Section 11 of the Constitution of
the State of South Carolina and venue is proper on the grounds that the actions giving rise
to the causes of action herein occurred in the County of Richland.
FACTUAL ALLEGATIONS APPLICABLE TO ALL CLAIMS
9. That Plaintiffs incorporate herein by reference all the allegations contained
in the above paragraphs and throughout this entire Complaint as though the same were fully
set forth herein at length.
10. That on or about January 28, 2020, during the 2019 – 2020 school year,
Plaintiff John Doe was a minor student at Ridgeview High School and a member of the
boys' basketball team.
11. Ridgeview High School’s boys’ athletic programs are school-sanctioned
and school-sponsored athletic programs.
12. Upon information and belief, Ridgeview High School’s boys’ athletic
programs have a history of hazing and violent abuse.
13. Upon information and belief, Defendant knew or should have known of
Ridgeview High School’s boys’ athletic programs history of hazing and abuse.
14. That upon information and belief, and at all times relevant herein,
Defendant Richland School District Two had the ability to control, supervise, and
monitor or should have known they had the ability to control, supervise, and monitor the
coaches, assistant coaches, staff, and students on the boys' basketball team, making them
liable for their actions and inactions that led to the damages Plaintiffs sustained.
15. That upon information and belief, and at all times relevant herein, the
actions and inactions complained about herein occurred on the premises of Ridgeview
High School.
16. That upon information and belief, and at all times relevant herein,
Defendant Richland County School District Two had the ability to control or should have
known they had the ability to control the boys on Ridgeview High School’s boys’
Basketball team, making them liable for their acts and conduct.
17. That on or about January 28, 2020, before a basketball game, several
members of Ridgeview High School’s boys’ basketball team violently sexually assaulted
Plaintiff John Doe while they were in the locker room.
18. That the members of the team who participated in sexually assaulting
Plaintiff John Doe by restraining him while another teammate punched him in the penis
and attempted to pull his pants down to put their fingers in Plaintiff John Doe’s anus.
19. During the same time, one of the members of the team was able to pull
down his underwear and was touching Plaintiff John Doe’s butt cheeks and trying to get
to his penis.
20. That Plaintiff John Doe fought as hard as he could to stop the sexual
assault and screamed for his sexual assaulters to get off of him while he was being
sexually assaulted. That several other boys from the team eventually heard what was
going on and came to the defense of Plaintiff John Doe, ultimately pulling the other boys
off of him.
21. That after being sexually assaulted by his teammates, Plaintiff John Doe
told his coach about the incident before the game started. Upon information and belief,
his coach told him that he would “deal with this” after the game.
22. That Plaintiff John Doe, was emotionally disturbed and upset immediately
following his sexual assault and chose to sit out the game.
23. That upon information and belief, the members of Ridgeview High
School’s boys’ basketball team that participated in sexually assaulting Plaintiff John Doe
had a group chat where they discussed and planned how they would sexually assault
other members of the team.
24. That Plaintiff John Doe told his mother about the sexual assault. That
Plaintiff Mother Doe was deeply upset and emotionally disturbed after being informed by
her son about the sexual assault and immediately informed the authorities about the
sexual assault and the details surrounding it.
25. That upon information and belief, the members of Ridgeview High
School’s boys’ basketball team that participated in sexually assaulting were criminally
charged by the Richland County Sherriff’s Department for their roles in sexually
assaulting Plaintiff John Doe.
26. Upon information and belief, law enforcement investigated the matter
after Plaintiff Mother Doe’s report and their investigation revealed multiple incidents of
sexual assault involving the same members of Ridgeview High School’s boys’ basketball
team who sexually assaulted Plaintiff John Doe.
27. That Defendant Richland County School District Two was under a duty to
prevent Plaintiff John Doe’s teammates from sexually assaulting him and other students
while on their premises and/or conducting themselves in a manner that created an
unreasonable risk of harm to others including, Plaintiff John Doe.
28. Notwithstanding information that Defendant knew or should have known,
Defendant took no reasonable measures to ensure that Plaintiff John Doe’s teammates
were not allowed to sexually assault him and other students.
29. That Defendant failed to properly ensure the safety and security of minor
students like Plaintiff John Doe from being sexually assaulted by his fellow teammates
and they failed to properly monitor and supervise Ridgeview High School’s boys’
basketball team from sexually assaulting their fellow teammates while on their premises.
30. That Plaintiff John Doe stopped playing for Ridgeview High School’s
boys’ basketball team after being sexually assaulted.
31. Upon information and belief, Defendant did not provide training to
administrators, teachers, coaches, or volunteers on sexual abuse or child abuse;
recognizing, investigating, or remediating student-on-student sexual assault and
harassment; or reporting child abuse or neglect.
32. That Plaintiffs suffered severe and permanent physical and emotional
injuries as a result of the Defendant’s inactions.
33. That as a proximate and actual result of Defendant’s negligent,
outrageous, carelessness, recklessness, wantonness, indifferent, and gross negligent
conduct, Plaintiffs, suffered and will in the future suffer severe pain, permanent
emotional distress, humiliation, mental anguish, indignity, loss of pleasures and
enjoyment of life which will in the future require psychological and psychiatric medical
care and treatment, and has caused and will in the future cause Plaintiffs to incur medical
costs.
34. That as a direct and proximate cause of the aforementioned incident,
Plaintiffs suffered emotional injuries from which they suffered and will continue to suffer
great physical pain, mental anguish and has caused loss of enjoyment of life.
FOR A FIRST CAUSE OF ACTION

NEGLIGENCE/GROSS NEGLIGENCE AND/OR RECKLESSNESS
36. That Defendants owed/owe a clear duty to Plaintiff John Doe and other
students while on school property and/or participating in school-sanctioned and school-
sponsored athletic programs.
37. That Defendant acting through its agents and servants were negligent,
careless, reckless, and grossly negligent at the time and place aforementioned in the
following particulars:
a) In failing to properly train, supervise, and monitor its staff, volunteers, and/or
agents;
b) In failing to provide a safe locker room for students, including Plaintiff John
Doe;
c) In hiring and retaining employees, agents, servants, volunteers, and/or

contractors that were not fit to work in the same setting with children,
including Plaintiff John Doe;
d) In failing to take reasonable precautions and safety measures for its students;
e) In failing to properly hire, train, and/or supervise its employees, staff,

volunteers, and/or agents;
f) In failing to have adequate policies and procedures in place to protect minor
students on their property, including Plaintiff John Doe;
g) In failing to act as a reasonably prudent entity would act under the same or
similar circumstances;
h) In failing to protect the minor Plaintiff;
i) In failing to enforce their own internal rules, policies, procedures, and

standards;
j) In any other such manner that Plaintiffs may become aware of through
discovery and/or at trial.
38. All of which were the direct and proximate cause of the damages suffered by
the Plaintiffs herein, said acts being in violation of the statutes and laws of the State of South
Carolina.
39. That as a direct and proximate result of Defendant’s negligence, gross

negligence, carelessness and/or recklessness, Plaintiffs were harmed and sustained serve
and permanent physical injuries, emotional distress, humiliation, mental anguish,
indignity, loss of pleasures, and enjoyment of life which required and will in the future
require psychological and psychiatric medical care and treatment.
40. That as a direct and proximate result of Defendant’s negligence and/or

recklessness, Plaintiffs have and will likely, in the future, be caused to incur medical
expenses.
41. That Plaintiffs are informed and believe that they are entitled to actual
damages in an amount that would adequately compensate them for their injuries and
damages.
FOR A SECOND CAUSE OF ACTION
OUTRAGE
42. That Plaintiffs incorporates herein by reference all the allegations contained
43. That the South Carolina Supreme Court recognized the actionability of the
tort of reckless infliction of emotional distress which is commonly known as Outrage.
44. That Defendant was negligent, grossly negligent, wanton and/or reckless
for the reasons outlined more fully herein.
45. That the negligence, gross negligence, wantonness and/or recklessness of

Defendant as further described herein, inflicted severe emotional distress on Plaintiffs.
46. That Defendant knew or should have known that their negligent, wanton
and/or reckless conduct would inflict severe emotional distress on Plaintiffs.
47. That Defendant’s negligence, gross negligence, wantonness and/or

recklessness was so extreme and outrageous that it exceeded all possible bounds of decency
and must be regarded as atrocious, and utterly intolerable in a civilized community.
48. That as a direct and proximate result of Defendant’s negligent and/or

reckless acts; Plaintiffs suffered injuries and damages as further described herein.

reckless acts; Plaintiffs suffered severe emotional distress that no reasonable person should
expect to endure.
50. That Plaintiffs’ emotional distress was of such nature so as to require them to
expend monies, to receive additional medical attention, and to require medical necessities.
51. That Plaintiffs have suffered and will continue to suffer physical pain,
humiliation, mental anguish, emotional distress, medical expenses, wage loss, and loss of
enjoyment of life.
damages in an amount which would adequately compensate them for their severe emotional
distress, injuries, and damages.
FOR A THIRD CAUSE OF ACTION
PREMISE LIABILITY
54. That Defendant owed a duty to reasonably protect Plaintiff John Doe, a
minor student at Ridgeview High School, from harm.
55. That Defendant knew and/or could have discovered through the exercise of
reasonable care that Plaintiff John Doe’s fellow teammates posed a risk of harm to students,
including Plaintiff John Doe.
56. That Defendant should have expected that Plaintiff John Doe, a minor school
student, would not discover or realize the dangers his fellow teammates posed to him on
their property and in their locker room, or protect himself against the actions described
herein.
57. That Defendant failed to exercise reasonable care to Plaintiff John Doe while
on their property and therefore breaching the duties Defendant owed to Plaintiffs.

reckless acts; Plaintiffs suffered injuries and damages as further described herein.
FOR A FOURTH CAUSE OF ACTION

NEGLIGENT SUPERVISION/ NEGLIGENT HIRING/NEGLIGENT
TRAINING/NEGLIGENT RETENTION
60. That Plaintiffs are informed and believe that Defendant through the
negligent, reckless, wanton, outrageous, and grossly negligent conduct of its employees,
volunteers, and agents are further negligent, willful, careless, reckless, and grossly
negligent in one or more of the following particulars:
(a) In failing to exercise the degree of care that a reasonably prudent school
district would have exercised under the same or similar circumstances;
(b) In failing to conduct a proper and adequate background search or review of

its employees, agents, servants, volunteers, and contractors before and after
hiring;
(c) In failing to monitor the conduct of its employees, agents, servants,

volunteers, and contractors and to take appropriate steps to discipline
and/or terminate them subsequent to the commissions of negligent,
outrageous, willful, wanton, reckless, grossly negligent and/or unlawful
acts;
(d) In failing to properly supervise its employees, servants, agents, volunteers,

and/or contractors;
(e) In failing to have in place adequate policies and procedures, and if such
policies and procedures were in place, in failing to enforce them;
(f) In failing to have in place adequate policies and procedures to mandate

compliance by its employees, agents, servants, volunteers and/or contractors
with state guidelines, statutes, laws, and regulations, and if such policies and
procedures were in place, in failing to enforce them;
(g) In any other such manner that Plaintiffs may become aware of through
discovery and/or at trial.
61. That all of which were the direct and proximate cause of the damages
suffered by the Plaintiffs herein, said acts being in violation of the laws of the State of South
Carolina.
62. That Plaintiffs have suffered and will continue to suffer physical pain,
humiliation, mental anguish, emotional distress, medical expenses, wage loss, and loss of
enjoyment of life.
damages in an amount which would adequately compensate them for their injuries and
damages.
FOR A FIFTH CAUSE OF ACTION
LOSS OF PERSONAL SERVICES
65. That Plaintiff Mother Doe is the natural guardian and mother of John Doe.
66. That as a direct and proximate result of the aforementioned actions and
inactions of Defendant, Plaintiff Mother Doe has been injured and damaged in Actual and
Consequential Damages as follows:
i. Pre-trial medical expenses; and
ii. Post-trial and future medical expenses until John Doe’s age of
majority.
67. That as a direct and proximate result of Defendant’s negligence and/or
recklessness, Plaintiff Mother Doe lost the services of her minor child which damaged,
Mother Doe. That Mother Doe’s child is not exposed to an increased risk of future harms
for which Mother Doe must remain vigilant as to protect her son.
68. That Plaintiffs are informed and believe that they are entitled to an award of
ACTUAL, CONSEQUENTIAL, PUNITIVE DAMAGES, costs, and reasonable attorney
fees for this cause of action.
FOR A SIXTH CAUSE OF ACTION

VIOLATION OF TITLE IX AND EDUCATION AMENDMENTS OF 1972
70. That Title IX of the Education Amendments of 1972 applies to an entire
school or institution if any part of that school receives federal funds. Upon information
and belief, Title IX applies to Richland County School District Two as it receives a wide
variety of federal fundingand grants.
71. That both the Department of Education and the Department of Justice have
promulgated regulations under Title IX that require a school to “adopt and publish
grievance procedures providing for the prompt and equitable resolution of student...
complaints alleging any action which would be prohibited by” Title IX or regulations
thereunder. 34 C.F.R. § 106.8(b).
72. That Upon information and belief, Plaintiff Mother Doe’s reports of sexual
abuse of Plaintiff John Doe, violated Title IX of the Education Amendments of 1972 [Title
IX], codified at 20 U.S.C. §§ 1681 et seq. and Title 34 Code of Federal Regulations Part
106.
73. That the essential purpose of Title IX is to eliminate discrimination on the

basis of sex in any educational program or activity receiving Federal financial assistance.
20 U.S.C. § 1681;34 C.F.R. § 106.1.
74. That upon information and belief, Title IX bestows a remedial and
affirmative action requirement on institutes of education to take such remedial action as
necessary to overcome the effects of such discrimination. 34 C.F.R. § 106.3(a).
Therefore, Title IX’s essential purpose to eliminate sex discrimination by definition seeks
to protect other individuals from the possibility of sex discrimination, and eliminating
known sexual discrimination, whether it be in the form of harassment or abuse, prevents
the future sexual harassment of other individuals.
75. That Title IX requires schools to designate at least one employee to

coordinate compliance with the regulations implementing Title IX. Upon information and
belief, despite Mother Doe’s reports to the administrators at Ridgeview High School, the
reports of sexual assault were actively concealed instead of being investigated by the
Title IX compliance officer. Additionally, the Plaintiffs are informed and believe that
there were previous reports of sexual abuse at Ridgeview High School and other
Richland County School District Two schools that were not investigated by Richland
County School District Two, thereby allowing the sexual abuse of minor students on their
premises, including Plaintiff.
76. That Title IX requires if a school district knows, or even reasonably should
have known, of sexual harassment or sexual assault, the school is responsible for taking
immediate effective action to eliminate the hostile environment and prevent its
recurrence. Upon information and belief, as a result of the sexual assaults being concealed
instead of properly investigated, policies and procedures to prevent sexual assault and
abuse at Richland County School District Two schools were not implemented thereby
subjecting Plaintiff John Doe to a hostile environment at school.
77. Further, Defendant violations of Title IX include the following particulars:
(a) In failing to take no action to protect Plaintiff John Doe, despite knowledge
of a need to supervise, discipline, warn, or take other corrective action to
prevent discrimination and harassment, including violent, gender-based
hazing and sexual assault occurring within the boys' basketball team and
other male sports programs;
(b) In being deliberately indifferent to and failing to take action on known

discrimination and harassment suffered by Plaintiff John Doe prior to the
sexual assault;
(c) In being deliberately indifferent to the known allegations of violent, gender-

based hazing, harassment, intimidation and the unique dangers to younger
male athletes;
(d) In failing to maintain and enforce an adequate policy against hazing and
bullying or, alternatively, being deliberately indifferent thereto;
(e) In creating a climate which tolerated violent, gender-based hazing,

harassment, and intimidation, including sexual assault and rape within the
Ridgeview High School’s boys' basketball team, or, alternatively, being
deliberately indifferent thereto;
(f) In failing to take appropriate action against the Ridgeview High School
boys’ basketball team and its members for misconduct occurring before and
following the sexual assault of Plaintiff John Doe or, alternatively, being
deliberately indifferent thereto, and thereby providing implicit approval,
encouragement, and ratification to continued misconduct;
(g) In failing to provide policy or training for its employees, faculty members,
coaches, or volunteers about sexual harassment and assault, sexual abuse,
child abuse, or mandatory reporting, despite allegations of abuse within
Ridgeview High School’s boys' athletics, thereby creating a climate where
such misconduct was tolerated and encouraged to continue without
consequence.
(h) In failing to conduct their own internal investigation into the sexual
assault and other allegations of misconduct and maintaining a policy of
refusing to conduct internal investigations in contexts where law
enforcement becomes involved;
(i) In failing to investigate, inform parents, and report harassment,

intimidation, and bullying occurring within Ridgeview High School’s
boys' basketball team
(j) In failing to report the sexual assault of Plaintiff John Doe to any and all
regulatory authorities having jurisdiction over the matter as a matter of law;
and
(k) In any other manner that Plaintiffs may become aware through discovery
and/or trial.
78. That as the direct and proximate result of the above-mentioned actions and
inactions of Defendant Richland County School District Two, Plaintiffs has been injured
and damaged in that they have been deprived of the rights, privileges, and immunities
afforded to the citizens of the State of South Carolina and the United States; has been
subject to sexual assault, physical and psychological injury; has endured and will endure
mental anguish and emotional distress; has endured a hostile learning environment; has
incurred medical bills, and will incur medical bills in the future; has been deprived of the
enjoyment of their lives, thereby entitling them to an award of ACTUAL,
CONSEQUENTIAL, PUNITIVE DAMAGES, costs, andreasonable attorney fees.
FOR THE SEVENTH CAUSE OF ACTION
VIOLATION OF CIVIL RIGHTS PURSUANT TO 42 U.S.C. § 1983
80. That Defendant created a danger to students, including Plaintiff John Doe,
through its adoption and perpetuation of a pattern, practice, and policy of allowing and
perpetuating, under color of law, violent, gender-based hazing and discrimination within
the boys’ basketball team and other male sports programs.
81. That Defendant had a duty to maintain and enforce a written policy or
rules prohibiting student hazing and failed to do so.
82. That Upon information and belief, Defendant has received repeated
complaints of sexual assault and harassment of male students, and deprivation of those
students’ constitutional rights at Ridgeview High School and other Richland County
School District Two schools.
83. That Defendant had a duty to maintain and enforce a policy and/or training
for their employees, administrators, faculty members, staff, volunteers, and other agents
regarding how to identify, investigate, and respond to student hazing and/or student on
student abuse and sexual assault, and failed to do so.
84. That Defendant has received repeated complaints of sexual assault and
harassment of male students, and deprivation of those students’ constitutional rights at
Ridgeview High School.
85. That Defendant’s absence of policies and failure to train its employees and
agents is closely related to or caused the discrimination and violent, gender-based hazing
against Plaintiff John Doe, violating his Constitutional right to bodily integrity and his
property right to education.
86. That Defendant had actual notice and knowledge of the dangers of sexual
harassment and assault faced by its young male student-athletes, and Plaintiff John Doe
specifically, yet took no meaningful remedial or disciplinary action, choosing not to
investigate or supervise activity in the boys’ locker room and elsewhere, which allowed
the discrimination, harassment, and violent gender-based hazing to occur.
87. That as a direct and natural consequence of Defendant’s action, inaction,
and deliberate indifference and violations of his Constitutional rights, Plaintiff John Doe
suffered, and continues to suffer, including but not limited to, physical injuries, emotional
distress, psychological trauma, and denial of education and educational opportunities.
88. That as a direct and proximate result of Defendant’s actions, inaction, and
deliberate indifference and violations of Plaintiff John Doe’s constitutional rights,
Plaintiff John Doe has been damaged in that he has been deprived of the rights,
privileges, and immunities afforded to the citizens of the State of South Carolina and the
United States; has been subject to sexual assault, physical and psychological injury; has
endured and will endure mental anguish and emotional distress; has incurred medical
bills, and will incur medical bills in the future; has been deprived of the enjoyment of his
life, thereby entitling him to an award of ACTUAL, CONSEQUENTIAL, PUNITIVE
DAMAGES, costs, and reasonable attorney fees for this cause of action.
WHEREFORE, Plaintiffs submit that each and every sexual assault presented
different injuries and damages which contributed to the overall injuries Plaintiffs suffered
as described above, and prays that they will be granted a judgment against the Defendant
as follows:
a. Actual damages on all causes of action;
b. Incidental damages on all causes of action;
c. Consequential damages on all causes of action;
d. Punitive damages on the FIFTH, SIXTH, and SEVENTH causes of action

asserted against Defendant;
e. For the costs and expenses of this action; and
f. For such other and further relief as the court may deem just and proper.
BAILEY LAW FIRM, L.L.C.
By: s/Tyler D. Bailey

Tyler D. Bailey
S.C. Bar No. 101915
1921 Henderson Street (29201)
P.O. Box 532
Columbia, SC (29202)
Telephone: 1-803-667-9716
Fax: 1-803-526-7642
Email: [email protected]
ATTORNEY FOR PLAINTIFFS
Columbia, South Carolina

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ELECTRONICALLY FILED - 2022 Jan 25 4:11 PM - RICHLAND - COMMON PLEAS - CASE#2022CP4000425

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

demanded in the Complaint and for a default judgment.

BAILEY LAW FIRM, L.L.C.

By: s/Tyler D. Bailey

would respectfully show unto this Honorable Court:

Plaintiffs Mother Doe and John Doe

are collectively referred to as “Plaintiffs”).

Defendant Richland County School District Two

District Two is a school district operated as a subdivision of Richland County

inactions of its agents, servants, contractors, volunteers, and employees.

this claim, took place at Ridgeview High School.

that caused the harm to Plaintiffs.

pursuant to principles of non-delegable duty, apparent authority, agency, ostensible

JURISDICTION & VENUE

to the causes of action herein occurred in the County of Richland.

FACTUAL ALLEGATIONS APPLICABLE TO ALL CLAIMS

9. That Plaintiffs incorporate herein by reference all the allegations contained

set forth herein at length.

boys' basketball team.

11. Ridgeview High School’s boys’ athletic programs are school-sanctioned

and school-sponsored athletic programs.

programs have a history of hazing and violent abuse.

Plaintiff John Doe while they were in the locker room.

other members of the team.

sexual assault and the details surrounding it.

assaulting Plaintiff John Doe.

team who sexually assaulted Plaintiff John Doe.

unreasonable risk of harm to others including, Plaintiff John Doe.

28. Notwithstanding information that Defendant knew or should have known,

were not allowed to sexually assault him and other students.

boys’ basketball team after being sexually assaulted.

administrators, teachers, coaches, or volunteers on sexual abuse or child abuse;

recognizing, investigating, or remediating student-on-student sexual assault and

harassment; or reporting child abuse or neglect.

injuries as a result of the Defendant’s inactions.

33. That as a proximate and actual result of Defendant’s negligent,

outrageous, carelessness, recklessness, wantonness, indifferent, and gross negligent

emotional distress, humiliation, mental anguish, indignity, loss of pleasures and

34. That as a direct and proximate cause of the aforementioned incident,

FOR A FIRST CAUSE OF ACTION

set forth herein at length.

students while on school property and/or participating in school-sanctioned and school-

sponsored athletic programs.

c) In hiring and retaining employees, agents, servants, volunteers, and/or

e) In failing to properly hire, train, and/or supervise its employees, staff,

h) In failing to protect the minor Plaintiff;

i) In failing to enforce their own internal rules, policies, procedures, and

39. That as a direct and proximate result of Defendant’s negligence, gross

40. That as a direct and proximate result of Defendant’s negligence and/or

45. That the negligence, gross negligence, wantonness and/or recklessness of

47. That Defendant’s negligence, gross negligence, wantonness and/or

48. That as a direct and proximate result of Defendant’s negligent and/or

49. That as a direct and proximate result of Defendant’s negligent and/or

58. That as a direct and proximate result of Defendant’s negligent and/or

FOR A FOURTH CAUSE OF ACTION

(b) In failing to conduct a proper and adequate background search or review of

(c) In failing to monitor the conduct of its employees, agents, servants,