A civil lawsuit filed in federal district court against the Steamboat Springs School District accuses multiple paraprofessionals of “cruel, discriminatory behavior” towards students with disabilities, according to the complaint and jury demand.

The 56-page complaint, along with a grand jury demand, was filed in the U.S District Court of Colorado in January, and lists five plaintiffs — the parents of the four minors who experienced the alleged abuse.

Seven defendants named in the federal civil complaint, including Steamboat Springs School District Superintendent Celine Wicks and five staff members, are accused of abusing and discriminating against the disabled students.

“The Steamboat Springs School District is committed to providing equal opportunities for all individuals in District programs and to providing a safe learning environment for all students,” said Wicks in a statement sent on Friday.

“We are aware of the allegations contained in the complaint that was filed. While we do not agree with many of the allegations and characterizations it contains, we cannot discuss those in detail at this time due to the active litigation,” she added.

According to the complaint, the students were “subjected to a ceaseless pattern of unacceptable, cruel and discriminatory behavior at the hands of (the) defendants,” including physical violence, neglect and verbal abuse.

The complaint also alleges the school district “failed to implement any meaningful measures to stop or prevent the abuse, neglect and discrimination, allowing it to continue,” and the district only acknowledged the treatment when the plaintiffs filed the complaint.

“The was not a momentary lapse or oversight — this was an institutional choice,” the complaint continues. “As a direct result of defendant SSSD’s action and inaction, these children suffered severe and irreparable harm.”

According to the complaint, 106 students were enrolled in the Special Education program in the 2023-2024 academic year at the high school, and six students were placed in a significant support needs classroom.

The four minors referenced in the lawsuit have been diagnosed with various disabilities. Three of the students are wheelchair-bound, and all four students are non-verbal, without the ability to communicate needs or describe abuse, according to the document.

Two of the students also require assistance using the bathroom, with one of the students needing regular adult diaper changes.

According to the complaint, former Steamboat Springs High School paraprofessional Sylvia Rawlings — one of the named defendants — told other paraprofessionals “she would have chosen to have an abortion if she had known her unborn child would have disabilities.”

The document also states that Rawlings allegedly threatened to hit a disabled student and kicked another student’s wheelchair.

In 2023, Rawlings faced three misdemeanor charges, including one count each of crimes against an at-risk person, child abuse and reckless endangerment, for spinning a disabled student around in their wheelchair, resulting in the student flipping out and onto the ground.

The fall caused the student to have an “enormous bulge” on the side of their head. The student also “demonstrated significant behavioral changes with regard to (their) eating and sleeping patterns,” according to the complaint.

Rawlings resigned from the school district after being charged. She then pled guilty to crimes against an at-risk person as an amended Class 1 misdemeanor, the document states.

“… Wicks was also aware of Defendant Rawlings’ history of hateful and abusive comments, as well as her mistreatment of students with significant support needs at SSHS,” the complaint states.

Rawlings, along with Steamboat Springs High School employee Dan Juba and former employee Chuck Rosemond, also allegedly did not provide the students with assistance to the bathroom, forcing one student to “sit in (their) soiled clothing for extended periods of time…,” the complaint states.

One student, who has a history of kidney failure, was allegedly forced to hold their urine for the entire school day, totaling more than nine hours, the complaint alleges.

The complaint further states that May 2023 video surveillance footage shows a school district employee pinning down a disabled student’s head with their foot. The employee is not named in the complaint.

The video footage also shows the employee “dragging” the students across carpeted floors in the high school, causing skin abrasions.

According to the complaint, the student came home with an “open head wound” and “carpet burns” on their back. The document notes that the parent of the student did not receive a notification from the school nurse about the injuries, but rather had to inquire.

The complaint also accuses Juba, Rosemond and Steamboat Springs School District employees Anne-Marie Tennyson and Ron Peterson of neglecting a student while they were responsible for their safety.

While under the care of Jube and Rosemond, the student’s “arm got stuck between his wheelchair and its wheel,” resulting in “large chunks of (the student’s) skin to be stripped off,” according to the court document.

The school nurse later suspected that the student’s “wound became infected after the accident due to it seeping fluid through the bandaging,” the complaint continues.

The employees are also accused of “routinely and openly exposing (the students’) genitalia to other students and staff at SSHS,” according to the complaint.

Disabled students were consistently changed in the significant support needs classroom rather than in a private bathroom or other private room, the complaint alleges.

“The students’ genitals were routinely exposed to students and staff … without their consent, violating their right to privacy and bodily integrity,” states the document.

According to the document, the named defendants also “regularly spoke to and about the students with condescension, anger and blatant disregard, often pretending as if the students were not present or incapable of understanding their words.”

During the time Rawlings worked at the school, she allegedly called a Black student a “monkey” on “multiple occasions,” the complaint alleges.

“Defendant Rawlings’ conduct was reported to (the school district), Wicks, Tennyson and/or Peterson, all of whom were deliberately indifferent to the conduct,” adds the court document.

Among the requests for judgment, the plaintiffs requested a trial “on all issues triable” on behalf of the plaintiffs; along with non-economic compensatory and consequential damages, “including damages for emotional distress, humiliation, loss of enjoyment of life and other pain and suffering on all claims allowed by law in an amount to be determined at trial.”

No future hearings or trial dates have been scheduled as of Friday afternoon, according to the federal clerk’s office for the District of Colorado.

Responding to the complaint in a statement on Friday, Wicks said “students and families can be assured that our top priority is, and will continue to be, providing a safe, supportive, and equitable learning environment for every student.”

“Since the 2022–2023 school year, when these allegations occurred, we have made significant leadership and system-wide changes to strengthen Special Education programs. This includes new leadership in key roles: a new principal at the high school and a new director of Exceptional Student Services overseeing special education.”

“For more than 70 years, we have served the children of Steamboat Springs, a responsibility we take very seriously,” Wicks continued. “We are proud of our accomplishments and remain dedicated to continuous learning and improvement, always seeking opportunities to do better.”