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![handle is hein.journals/addendum104 and id is 1 raw text is:
104 N.C. L. REV. F. 1 (2025)
Case Brief: Ricketts v. Wake County Public School System*
INTRODUCTION
When sophomore Davina Ricketts ran for student council at Wake
County's William G. Enloe High School (Enloe),1 her goal was to increase
the diversity in her school's student leadership.2 Unfortunately, her efforts
resulted in severe racial harassment from other students.3 When Davina turned
to the school for recourse, she was met with indifference by the school district
and administrators who did little to intervene and at times even seemed to
contribute to the hardship she faced.4 Davina brought suit in the United States
District Court for the Eastern District of North Carolina, alleging Title VI
claims against the Wake County Public School System, the Wake County
Board of Education, and various school administrators.5 The district court
dismissed Davina's complaint for failure to state a claim, leading her to appeal
to the Fourth Circuit, which ultimately reversed.6 In holding that Davina
sufficiently alleged deliberate indifference, retaliation, and equal protection
claims, Ricketts v. Wake County Public School System' marked the first time the
Fourth Circuit recognized Title VI claims for student-on-student racial
harassment.! Ricketts thus opened the door for more comprehensive recourse
when students face invidious discrimination in the very spaces designed to
foster their growth, sense of belonging, and potential to succeed.
* © 2025 Mary Anneliese Childs.
1. The Wake County public school system serves central North Carolina, with its county seat
located in the state capital of Raleigh. Wake County Public School System, North Carolina, BALLOTPEDIA,
https://ballotpedia.org/WakeCountyPublicSchoolSystem,_NorthCarolina [https://perma.cc/
VVE6-HNS2]. More than 161,000 students across 203 schools attended Wake County public schools
during the 2025-2026 school year, making it the largest school district in North Carolina. District Facts,
WAKE CNTY. PUB. SCH. SYS., https://www.wcpss.net/domain/22671 [https://perma.cc/YD63-JPKP];
T. Keung Hui, Could Lawmakers Break Up Wake, CMS? Bill Would Study NC's 5 Largest School Districts,
NEWS & OBSERVER (Feb. 12, 2025, at 17:15 ET), https://www.newsobserver.com/news/politics-
government/article300077249.html [https://perma.cc/FSJ3-JGTV (staff-uploaded archive)].
2. See Ricketts v. Wake Cnty. Pub. Sch. Sys., 125 F.4th 507, 514 (4th Cir. 2025). Because this
case was decided at the motion-to-dismiss stage, all facts Davina pled in her Second Amended
Complaint were taken as true for purposes of determining whether she stated a claim for relief. To
avoid repetitive phrasing in this Case Brief, I present the facts as Davina asserted them in her complaint
without continuously noting that they remain unproven and have not been adjudicated as true.
3. Id.
4. Id.
5. Id.
6. Id.
7. 125 F.4th 507 (4th Cir. 2025).
8. Id. at 520-21.](ViewImageLocal?handle=hein.journals/addendum104&div=1&collection=&method=preview&ext=.png&size=3)