In M.S. v. Susquehana Twp. Sch. Dist., a private action under Title IX, the plaintiff sought damages for injuries suffered as a result of harassment from her assailant principal. In order to sustain the claim, the plaintiff had to plead that an “appropriate person” who had knowledge of the alleged wrongdoing failed to take corrective action. The 3rd Circuit held that the perpetrator — the assistant principal in this case — could not be that “appropriate person.” In so ruling the Court relied heavily on Gebser v. Lago Vista Indep. Sch. Dist.