April 11, 2017

SAN ANTONIO, TEXAS

FOR IMMEDIATE RELEASE

FEDERAL LAWSUIT FILED CONCERNING LA VERNIA HAZING

Family of John Doe rape victim seek injunctive relief and monetary damages

The parents of a La Vernia High School football player filed a complaint in the Southern District
of Texas, San Antonio Division, on Thursday, seeking injunctive relief and monetary damages
arising from their sons sodomization as part of a team initiation ritual, allegedly known about
by administrators and coaches in the La Vernia Independent School District.
The complaint, also names La Vernia ISD Superintendent Jose H. Moreno, La Vernia High School
Principal Kristen Martin, La Vernia High School Athletic Directors Brandon Layne, Richard
Hinojosa, and coaches Chris Taber, Scott Grub, and Keith Barnes.
The lawsuit seeks damages for civil rights violations under Federal law, as well as the 4th and 14th
Amendments of the United States Constitution. Specific factual allegations include:
The subject hazing rituals and traditions are a form of bullying and have been part
of the culture of the Schools football team for at least a decade, according to news
accounts, and possibly longer. The teams coaches have sanctioned these rituals,
while other school officials, including La Vernia ISD and the Schools principal,
athletic director, and coaches, turned a blind eye toward the abuse, even after the
abuse was reported to them. Indeed, the Plaintiffs are but a fraction of the students
who have been physically and sexually assaulted pursuant to these sadistic hazing
rituals which include rape, sodomy, unlawful sexual penetration, and sexual abuse.
In addition to seeking damages to compensate Plaintiffs for their psychological
injuries, CHILD DOE, who still attends the School, also seek injunctive relief that
will put an end to the hazing rituals, so that neither they nor future members of the
Schools football team will be subjected to the same abuses Plaintiffs have suffered.
The lawsuit is based on alleged violations of 42 U.S.C. 1983 and 1988, and the deprivation
under color of state law and through state law claims of willful and wanton violation of CHILD
DOEs rights, as secured by the United States Constitution, including the 5th and 14th Amendments,
to recover damages resulting from the Defendants mistreatment and neglect of CHILD DOE
including deliberate indifference to peer based sexual harassment, pursuant to Title VI, 42 U.S.C.
1681(a).
Attorney J. K. Ivey of the Marquardt Law Firm says that the complaint is but the first step in an
effort to peel back the covers on a long and sordid history of neglect, misconduct, and abuse at La
Vernia High School involving dozens of children over a decade or more. The national news
attention on this story is causing former students and athletes to come forward with their own
accounts of whats gone on at La Vernia High School. We believe the evidence will show a
pattern of deliberate neglect covering many years.
The family of CHILD DOE is appealing to anyone with knowledge concerning the hazing rituals
at La Vernia High School to contact their attorneys.
Attorney Ivey states that the Defendants in the suit will be served with a Summons to answer and
appear in Federal court.
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If you would like more information about this topic, or to schedule an interview with J. K. Ivey,
please contact the Marquardt Law Firm, P.C., at (210) 530-4278, (512) 695-1334 (cell) or
jkivey@jkivey.com