School District Submits Response To Bullying/Sexual Harassment Lawsuit

A legal case concerning Hanover High School looks to be heading to court this month after the attorney representing the Dresden School District responded on February 2nd to a November 2017 lawsuit accusing the district and other entities of breaking the law by failing to properly address the bullying of a student on campus. The response largely denies the charges being brought against the defendants, which are the Dresden School District, School Administrative Unit #70, and Hanover High School Principal Justin Campbell.

The lawsuit, which was filed by attorney Karen Hewes for a 15-year-old boy who attended Hanover High School during the 2016-2017 school year as a freshman and his mother (who go by the initials A.V. and N.V. respectively in order to protect their identities), claims that the boy was the victim of extensive bullying and sexual harassment from fellow students while he was at Hanover. According to the lawsuit document, the abuse became so bad that A.V. had to leave Hanover High School after his freshman year and moved to South Burlington, Vt.

A.V. and his mother go on to say that school and district officials including Principal Campbell did not take enough action to stop the bullying and protect A.V. despite multiple requests from A.V.’s parents throughout the school year. On these grounds, they argue that the Dresden School District and SAU #70 violated Title IX (the federal law that prohibits discrimination and hostile working environments on the basis of sex in schools that receive federal funding, including Hanover High) and that Principal Campbell is guilty of negligence. Additionally, the lawsuit claims that all three defendants should be punished for failing to protect A.V.’s rights while in positions charged with enforcing rules protecting students under the Title 42 of the U.S. Code. For these claimed transgressions, the boy’s family is asking for compensation.

The response, which was submitted by their attorney Dona Feeney, denied that the school district and Principal Campbell had broken the law and called for the dismissal of all three charges being brought against them. As part of these assertions, the defendants call into question the accuracy of many of the plaintiffs’ claims about how much the school administration knew about the bullying as well as those about the level to which the bullying took place in the school. They also contested parts of A.V.’s parents’ accounts of their dealings with the school’s administration over the bullying.

Claims laid out in the lawsuit and in the response are summarized below. It should be noted that, as of now, these are all allegations and therefore cannot be fully confirmed.


The events that the defendants refer to in their response can be found in a long list detailing when the plaintiffs claim that A.V. was bullied and when A.V.’s parents claimed to have sought help from the school administration (including times when they felt the administration had failed to protect their son). At least 11 fellow students are listed as perpetrators, usually referred to by a letter (i.e. Student A, Student B, etc.). A number of incidents are recorded, including instances in which other students referred to A.V. using names like “Little D” in addition to sexual and gender-based slurs. The lawsuit also alleges that students would put locks on A.V.’s bags to prevent him from opening them, post embarrassing pictures of A.V. on social media, put up posters in places like the school cafeteria that contained manipulated images of A.V. without his consent, and draw pictures of male genitalia on A.V.’s boots.

Physical altercations were prominently mentioned, including an occasion when a student “slammed [A.V.’s head] into the corner of the piano located in the hallway,” leaving A.V. with “a large, swollen bump on his forehead, bruising and a concussion”. The lawsuit also details times when A.V. was punched at lacrosse practice and an incident when A.V. was concussed in a fight in the HHS boys’ locker room (an event which was filmed by another student and posted online). After this incident, A.V. was placed on medical leave and no longer returned to attending Hanover High. The document states, “Ultimately, A.V.’s family requested to have him reassigned to another school, which the [then] Superintendent [Frank Bass] agreed would be in his best interest.”

Although they did not occur during the school year, the lawsuit also mentions incidents of abuse from a summer camp that A.V. was part of right before entering high school. There, the plaintiffs allege that other students spread their semen onto A.V.’s possessions and body, and insulted his body image, among other things. The lawsuit later suggests that “A.V. was repeatedly subjected to sexual harassment based upon his harassers’ perception that he did not conform to male norms.”

The lawsuit claims that the plaintiffs contacted and spoke with members of the school administration such as Campbell on numerous occasions throughout the school year. They allege that these officials did not investigate all of the incidents that A.V.’s parents had notified them of.


In their response, the defendants agree that A.V. did face some of the harassment mentioned in the lawsuit. However, they dispute the way that many of the events listed in the lawsuit are portrayed and in some cases directly denied certain allegations.

The defendants often denied that the aforementioned events had taken place in the way described in the lawsuit by citing a lack of evidence and/or awareness on their own end. They frequently responded to points laid out in the lawsuit by writing, “The Defendants are without knowledge sufficient to determine the truth or falsity of these allegations and must deny same.”

The response rejected the plaintiffs’ recollection of events at times. On the subject of name-calling, the defendants claim that they thought A.V. “called himself ‘Little D’ and encouraged others to call him that.” Other alleged inconsistencies in the lawsuit that the defendants mentioned include the description of the poster incident (the school district claims that a poster was never posted on Hanover High School premises and that the poster had instead been created at the Hartford Tech Center) and the circumstances surrounding the May 2017 locker room fight; the report notes that “contemporaneous witnesses recounted that A.V.
was the aggressor in this incident.”

Additionally, the defendants suggested that some of the listed incidents, such as the sexual harassment at the summer camp, did not bear much relevance to the case because it took place outside of the school year at a camp that was not affiliated with the school.

The plaintiffs’ account of meetings with Principal Campbell and the school administration are also heavily disputed. In particular, the lawsuit’s allegations about Campbell’s statements in talks with A.V.’s parents about their son’s situation (including one claim accusing Campbell of saying boys do these kinds of things to each other) were denied. The amount of information that the parents shared with the school is also questioned. The defendants maintain that the school investigated the school-related incidents brought before them by A.V.’s parents and dealt with what they were able to find accordingly.


Some of the involved parties in the case provided little comment when contacted. Principal Campbell declined to be interviewed, writing in a February 8th e-mail, “I’m unable to comment as all aspects of this case involve student records. FERPA (the Family Educational Rights and Privacy Act) provides strict confidentiality in these matters.”

Karen Hewes, the lawyer representing A.V. and his mother, declined an interview over e-mail. However, according to a February 7th article in the Valley News by Rob Wolfe, Hewes reacted to the school district’s response by saying, “The response does not provide any new information. Instead it underscores the fact that when reports of sexual harassment are made, the victim’s character is scrutinized, he or she is discredited, and the perpetrators are believed.” She went on to state, “As I stated before this is a systemic issue that we are seeing across all avenues of society, including our public schools. My clients stand behind their complaint.”

Both the plaintiffs and the defendants stated that they wanted a jury trial at the U.S. District Court in Concord, NH. According to the Valley News, a pretrial conference between the parties has been set for February 22nd.
Note: Special thanks to Rob Wolfe of The Valley News for providing copies of the legal documents pertaining to the case.

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