An unidentified mother has filed suit on behalf of her 16-year-old daughter, who she says had sexual relations with a 36-year-old music teacher.
The mother, identified only as Jane Doe throughout the complaint, claims Matthew Lang, a music teacher at Alton High School, performed sexual activity with her daughter, identified only as Mary Doe, from February through August 2009.
Lang was arrested by Madison County Sheriff's Department Aug. 13 on criminal sexual assault charges for allegedly having a sexual relationship with a student.
"That prior to said sexual acts, the Defendants, by and through their employees and agents, had been warned that Matthew Lang was conducting himself improperly towards the minor Plaintiff in that he was seen taking the minor Plaintiff to and from Alton High School in his private automobile," the suit filed Aug. 26 in St. Clair County Circuit Court states.
Mary Doe's parents advised Alton High School Principal Barbara Gillian of Lang's inappropriate conduct, and Gillian promised to investigate Lang and to take appropriate measures to protect Mary Doe, the complaint says.
Named as defendants in the suit are Alton Community Unit School District No. 11 and the Board of Education of Alton Unit Community School District No. 11, who Jane Doe says failed to properly screen Lang before hiring him, hired Lang when they should have discovered he was the type of person to engage in sexual activities with his students and failed to take appropriate action to prevent further contact between Lang and Mary Doe.
In addition, both defendants negligently retained Lang after they knew of his inappropriate conduct, failed to abide by its promises that appropriate actions would be taken against Lang, failed to report Lang's conduct to police and failed to maintain discipline, according to the complaint.
The complaint says that both defendants discovered Lang was guilty of inappropriate conduct with students other than Mary Doe, but failed to take appropriate action
Because of Lang's conduct, Mary Doe suffered bodily injury, mental injury, pain, loss of enjoyment of life, loss of a normal life, humiliation and embarrassment, which caused Mary Doe to undergo psychological care, the suit states.
Jane Doe says she incurred medical expenses in caring for her daughter's psychological care.
In the two-count suit, Jane Doe is seeking a judgment of more than $100,000, plus costs.
Thomas O. Falb of Williamson, Webster, Falb and Glisson in Alton will be representing her.
Madison County Circuit Court case number: 09-L-886.