ST. LOUIS - A Jane Doe filed a lawsuit on July 16 in Circuit Court for the County of St. Louis against Kirkwood R-7 School District and John "Jack" Collier for sexual assault and battery.
According to the complaint, Jane Doe suffered sexual abuse, sexual harassment, and/or sexual discrimination in the 1980-1981 academic year while she was a minor child and student at Kirkwood by Collier.
Kirkwood administrators were policy makers and/or administrators who had a duty to train, yet failed to train, administrators, employees, staff, students, and parents concerning sexual discrimination and harassment against students and failed to investigate and stop sexual harassment of students.
Doe alleges that during the 1980-1981 academic year, Collier became infatuated with her and took an inappropriate sexual, romantic, and/or intimate interest in her with a campaign of open and obvious sexual advances, sexual comments, stalking, and/or abuse towards her.
It is alleged that Collier’s conduct was witnessed in whole or in part by numerous Kirkwood employees, including administrators and/or board of education members with the authority to take corrective disciplinary action. Collier’s abuse of Doe led to him raping, sodomizing, and/or abusing her, but prior to the incident, Collier was caught stalking Doe by Doe's mother, including an incident in which Collier showed up to Doe's residence uninvited at nighttime and began throwing small objects at Doe's bedroom window, the suit claims.
Doe's mother called Kirkwood administrators in the days thereafter to inform them of Collier’s inappropriate and illegal conduct but nothing was done about Collier's behavior, the suit says. Doe alleges that she repressed the memories of her trauma until June or July 2020 when numerous victims described the abuse they suffered at Kirkwood in a Facebook group for Kirkwood alumni.
Doe is represented by Grant C. Boyd of The O'Brien Law Firm, P.C. The defendant has removed the case to St. Louis federal court.