E. GRADY JOLLY and W. EUGENE DAVIS, Circuit Judges:
Jane Doe was sexually molested by her high school teacher in Taylor, Texas. Defendant Eddy Lankford, principal of Taylor High, and defendant Mike Caplinger, superintendent of the Taylor Independent School District, were sued in their supervisory capacity by Jane Doe for permitting violations of her substantive due process right to bodily integrity. The district court denied their claim of qualified immunity, and they have filed this interlocutory appeal on that issue. We hold, first, that schoolchildren do have a liberty interest in their bodily integrity that is protected by the Due Process Clause of the Fourteenth Amendment and that physical sexual abuse by a school employee violates that right. Second, we hold that school officials can be held liable for supervisory failures that result in the molestation of a schoolchild if those failures manifest a deliberate indifference to the constitutional rights of that child. Next, we conclude that each of these legal principles was clearly established in 1987, when the violations took place. Finally, in analyzing whether Caplinger and Lankford fulfilled the duty that they owed to Jane Doe, we reverse the district court’s denial of immunity to defendant Caplinger, but we affirm its denial of immunity to Lank-ford.
[446]*446I
FACTS1
Defendant Jesse Lynn Stroud, a twenty-year veteran of Texas’s public education system, was employed by the Taylor Independent School District as a biology teacher and assistant coach from 1981 until 1987. It was no secret within the school community that Coach Stroud behaved inappropriately toward a number of young female students over the course of his employment at Taylor High. He made little effort to conceal his fancy for these female students: he wrote notes to them, he let them drive his truck, he exhibited explicit favoritism toward them in class, and often touched them in an overly familiar, inappropriate way.
Defendant Eddy Lankford became the principal of Taylor High in August 1983. By the fall semester of 1985, complaints about Stroud’s behavior had reached his office through various channels. During the previous 1984-1985 school year, Stroud had “befriended” one of his female freshman students. Their friendship far transgressed the boundaries of a normal, appropriate teacher-student relationship. Stroud frequently placed candy, flowers, and other gifts in her locker, and the two were often seen exchanging notes. He allowed her to take her friends to lunch in his truck. He wrote excuses for her when she was late for other classes. He often walked her to class, prompting students openly to tease Stroud about his relationship with this girl. Stroud also engaged in overt favoritism in his biology classes. Female students were not required to do classwork or to behave; they often wandered around the classroom, left the classroom during the class period, or changed, their grades in Stroud’s gradebook. Conversely, male students (with the exception of certain athletes who were coached by Stroud) were made to submit classwork, take tests, and generally behave like regular students.
By the fall of 1985, approximately one year after their “relationship” had begun, rumors about Stroud and the freshman student (by then a sophomore) were circulating not only among students and faculty but also among the town residents of Taylor. Stroud’s favoritism in the classroom was also well-known within the school community. In addition, Stroud had also befriended a new female freshman student, and began a similar inappropriate relationship (note-writing, gift-giving, walking to class, etc.) with her. Principal Lankford approached Stroud outside the fleldhouse during the 1985 football season and spoke to him about being “too friendly” with the sophomore student.
Also during the fall of 1985, the school librarian, Mary Jean Livingood, received telephone calls from two friends whose children were students in Stroud’s biology class. Both mothers complained about Stroud’s favoritism toward certain students in the classroom and his use of sexual innuendo in his biology lectures. Livingood had also seen Stroud engaging in unprofessional conduct; he often grabbed girls around the waist from "behind in the hallways or excessively hugged girls while putting his arms around them. Livingood reported the inappropriate behavior she had witnessed to Principal Lankford and also informed him of the two telephone calls she had received from parents. Additionally, one of the mothers who had initially called Livingood also called Lankford to complain about Stroud’s favoritism in the classroom. Although Lankford claims that he spoke with Stroud about these complaints, Stroud does not recall any such meeting.
In the spring of 1986, guidance counselor Naomi Pasemann noticed a group of girls gathered around Stroud’s desk before school one day; one of the girls was sitting on top of the desk, while Stroud was seated behind the desk with the rest of the girls around him. Pasemann told Lankford about this incident; the two also discussed Stroud’s practice of allowing unlicensed freshmen to drive his truck. Later that spring, the mothers of two female students in Stroud’s biology class met with Lankford and complained [447]*447about Stroud’s overt favoritism toward certain girls in the class. Lankford suggested that their daughters were “a little bit jealous” of those girls in the favored group.
In May of 1986, Livingood reported to Lankford that she had witnessed an episode of “child molestation” involving Stroud and two freshman female students. Livingood noticed that the lights in the copy room at the library were off; as she approached the room, she heard loud laughing and talking. When she looked into the room, she saw Stroud lifting the female students onto a table and catching them as they jumped off of the table into his arms. She insisted that Stroud stop the behavior. She immediately reported the incident to Lankford.
Lankford downplayed the incident. He told Livingood that he put his arms around cheerleaders at pep rallies all the time, and joked that he had invented the popular “pro-hugging” bumper stickers often seen on automobiles.2 Livingood explained that the behavior that she witnessed was of a different ilk, was inappropriate, and was akin to “child molestation.” When Stroud later approached Lankford to discuss the incident, the two men agreed that the librarian had overreacted. Lankford did not warn or discipline Stroud — even mildly — for any incident or conduct. Indeed, Lankford failed to document any of the complaints he received about Stroud.
All of this behavior occurred before defendant Mike Caplinger ever moved to Taylor or worked for the Taylor Independent School District. Caplinger became the superintendent of the Taylor ISD in July 1986; Lank-ford did not inform Caplinger of any problems — real or potential — with' Stroud or with his pattern of conduct.
Plaintiff Jane Doe entered Taylor High as a freshman in August 1986; she was a student in Stroud’s biology class. Stroud began his seduction of Doe by writing personal— often suggestive — comments on her homework and test papers. The two began exchanging notes and telephoning each other; he often walked her to-class. Stroud took Doe and her friends to lunch during the school day and bought alcoholic beverages for them. He did not require Doe to do classwork or to take tests, yet she received high grades in Stroud’s class. Not surprisingly, all of this attention flattered Doe, and she developed a “crush” on Stroud.
By late fall, Stroud was touching and kissing Jane Doe. It began with a kiss on her cheek as she was leaving the school field-house one day. Eventually, he began taking her into the laboratory room adjacent to his classroom and to the fieldhouse to engage in kissing and petting. Their physical relationship escalated to heavy petting and undressing in January 1987, when Stroud took Doe and some of her friends, including his own daughter, to a rock concert. There, he bought her alcoholic beverages, took her back to the fieldhouse, and began caressing her in the most intimate of ways. He suggested intercourse, but she refused.
Rumors about Doe and Stroud were rampant among the students and faculty by this time. The two were constantly together— walking to class, riding in the car, going out to lunch. Doe often went to Stroud’s classroom during other class periods. Coaches and students frequently teased Stroud about his relationship with Doe, often mentioning the two freshman girls he had befriended during the two previous years. Sometime in January 1987, Lankford heard that Stroud had taken Doe and other students to the rock concert; that month he also received complaints from four female students in Stroud’s biology class about Stroud’s favoritism toward certain students. Lankford spoke with Stroud about this complaint, and, for the first time, notified Caplinger about possible problems with Coach Stroud.
In early February 1987, Mickey Miller, the assistant principal of Taylor’s middle school, reported to Caplinger that at a basketball game he had witnessed Stroud behaving inappropriately with several freshman girls, including Jane Doe. Instead of sitting with the team, Stroud was sitting with the girls engaging in horseplay — the girls played with his hair as he halfheartedly “defended” him[448]*448self. Caplinger instructed Lankford to speak with Stroud about this incident, which he did; the athletic director, Eddy Spiller, also spoke with Stroud about the report. Spiller later told Lankford that he had asked Stroud if Stroud was “fooling around with any of these little old girls,” and that Stroud had denied any such behavior. Lankford acknowledges that he did not ask Spiller what prompted him to confront Stroud with this direct question.
On Valentine’s Day, Stroud gave Jane Doe a valentine that read: “To my most favorite, prettiest, sweetest, nicest sweetheart in the world! Please don’t change cause I need you. I’m in love with you. Forever — for real — I love you.” A friend and classmate of Jane Doe’s, Brittani B., found the valentine in Doe’s purse and took it to Pasemann, the guidance counselor. Brittani told Pasemann about the exchange of notes and gifts between Doe and Stroud, and shared her suspicions that the two were having a sexual relationship. Pasemann told Brittani that she had heard the rumors about Stroud and Doe, and instructed her to take the note to Principal Lankford.
Brittani took the note to Lankford the next day; when she went into his office, he insisted that a witness be present for the meeting to ensure, according to him, “that rumors won’t start like those about Stroud and [Doe].” Lankford examined the note and admitted that the handwriting looked like Stroud’s, but told Brittani that he had no proof that it was from Stroud because it was not signed. Lankford told Brittani that Stroud merely had a way of flirting with the girls, and that such behavior was Stroud’s “way of doing things.” Lankford did not keep a copy of the note and did not investigate the matter further; he did not tell Superintendent Caplinger about the incident, nor did he speak with Stroud or Doe. His only action was to transfer Brittani out of Stroud’s biology class.
After a school-sponsored Valentine’s Day dance, Jane Doe spent the night at Stroud’s home; Doe had befriended Stroud’s daughter, and Stroud had invited Doe to spend the night. While Doe was there, Stroud again suggested to her that they have intercourse. Once again, she refused. She spent several nights at the Stroud home over the next few months. In late March or early April 1987, Stroud and Doe had intercourse for the first time. She was fifteen years old. Stroud was her first sexual partner.
Over the next several months, Stroud and Doe had repeated sexual contact. Sex occurred at different locations, both on and off the school grounds. Their romantic relationship — although perhaps not the extent of it— was common knowledge within the Taylor High community, not only among students, but also among the faculty and the parents of many students. Lankford asked a friend whose daughter was a student at the high school to “keep his ears open” for information about Doe and Stroud. On Stroud’s performance evaluation by Lankford for the 1986-1987 academic year, however, there was nothing to indicate that Stroud’s performance was anything less than fully satisfactory. Indeed, Lankford still had not even informally documented any incident or pattern of conduct relating to Stroud.
In June 1987, Stroud took Doe and some other girls, along with his family, to a local fair, the Com Festival, where he once again provided them with alcoholic beverages. At least one of the girls became intoxicated. Stroud’s wife angrily left the festival when Stroud began dancing with Doe. Stroud and Doe left the festival together, went out to a field, and had sexual intercourse. Later, he and Doe went to his home, where Doe spent the night, and had intercourse again. Two concerned parents, both prominent members of the community, reported to Caplinger that Stroud was behaving inappropriately with Jane Doe at this festival, that Mrs. Stroud had left the festival because of his behavior, and that there was a possibility that he and Doe had left the festival together. One of the parents also showed Caplinger notes that Stroud had written to his daughter.
In response to the report, Caplinger contacted the parents of the girl who, according to the story, was intoxicated and misbehaving at the festival in the company of Doe and Stroud. When the girl’s mother assured him that her daughter had not even been at the festival, that she had been sick and at home, [449]*449Caplinger dismissed the report as unfounded without investigating further or contacting Jane Doe’s parents to discuss the report with them.
Caplinger was by now aware of the rumors about Stroud and Doe and the reports of his favoritism in the classroom. He contacted the school’s attorney to discuss the situation concerning Stroud, and, apparently at Ca-plinger’s instruction, Lankford contacted the Texas Education Authority to see if there were any reports about Stroud concerning any inappropriate behavior at the schools where he had previously been employed. Lankford was told that there were no reports specifically naming Stroud, but that the Authority had received an anonymous tip about an inappropriate relationship between a coach and a student at Taylor High.
In July 1987, Doe’s parents discovered photographs of Stroud among Doe’s possessions with such handwritten inscriptions by Stroud as: “Please don’t ever change and don’t ever leave me. I want to be this close always — I love you — Coach Lynn Stroud.” Doe’s parents immediately scheduled a meeting with Caplinger. At the meeting, they showed him the photographs. Caplinger confirmed to them that he was aware of rumors concerning Stroud and Doe and told them about the Corn Festival incident. He promised to convene a meeting of all the parties involved. After speaking with Doe’s parents, Caplinger spoke with Jane Doe privately in his office. He showed her the photographs her parents had just presented to him and inquired about the nature of her relationship with Stroud. Doe suggested that the notes on the photos were just “friendly gestures.” She explicitly denied any sexual relations with Stroud.
Caplinger called Lankford after the meeting with the Does, who in turn called Stroud. Upon receiving the message, Stroud sought out Lankford; before Lankford had a chance to explain to Stroud that there had been a meeting with the Does concerning some photographs that he had given to Jane, Stroud vehemently denied any sexual involvement with Doe. For the first time, Lankford spoke of disciplinary consequences. Lank-ford suggested to Stroud that he resign or take an in-sehool suspension (which would relieve him of his classroom duties), but Stroud refused. Lankford and Stroud then went over to Caplinger’s house at approximately 9:30 p.m. that evening. Caplinger, who had guests in his house, left his house and went to his office accompanied by Lank-ford and Stroud. There, the three men discussed the situation. Caplinger and Lank-ford warned Stroud to keep his distance from Jane Doe, and that he would be fired “if something was going on.” No further action was taken, however; the meeting that Ca-plinger had promised to schedule never took place, and Stroud did not hear from either Lankford or Caplinger again until October 6, the day he was suspended from employment.
Although Jane Doe was able to stay away from Stroud for the remainder of the summer vacation, when classes resumed in the late summer of 1987, Stroud’s sexual advances towards her resumed as well, and soon thereafter they began having intercourse again. Lankford admits that he watched Stroud no more closely than he previously had. The sexual contact continued into the fall of Jane Doe’s sophomore year, until October 5, when Doe’s mother found more love letters from Stroud among Jane’s possessions. The Does then consulted their family lawyer, who agreed to discuss the matter with Jane. Upon meeting with Jane, the attorney learned the truth about her sexual involvement with Stroud. Doe explained that she had kept the matter a secret because she feared the repercussions of disclosure.
The attorney reported the information to Caplinger at once. Coincidentally, on the same day, the mother of another female student contacted the administration to report that her daughter had also been victimized by Stroud; Stroud had grabbed the student’s buttocks in class that day. Caplinger ordered Stroud immediately suspended from employment. Stroud later resigned his position and pled guilty to criminal charges stemming from his molestation of Jane Doe.
II
PROCEDURAL HISTORY
Jane Doe brought this § 1983 civil rights lawsuit against Stroud, the school district, [450]*450Superintendent Caplinger, and Principal Lankford. She charged inter alia that these defendants, while acting under color of state law, deprived her of her constitutional rights guaranteed by the Fourteenth Amendment’s Due Process and Equal Protection Clauses, in violation of 42 U.S.C. § 1983. Following the denial of their motions for summary judgment on qualified immunity grounds, Ca-plinger and Lankford filed this appeal. Both contend that they are entitled to qualified immunity because: (1) Jane Doe was not deprived of any constitutional right when she was sexually molested by Coach Stroud; (2) even if Doe was deprived of a constitutional right, they owed her no duty in connection with this constitutional violation; (3) even if Doe was deprived of a constitutional right and they owed her a duty with respect to that right, these issues of law were not “clearly established” in 1987 when the violations took place; and (4) in any event, their response to the situation satisfied any duty that they owed to Doe.
Ill
DUE PROCESS
A
The first step in deciding whether Caplinger and Lankford are entitled to claim qualified immunity from this lawsuit is to determine whether the Constitution, through the Fourteenth Amendment’s substantive due process component, protects school-age children attending public schools from sexual abuse inflicted by a school employee. “Section 1983 imposes liability for violations of rights protected by the Constitution, not for violations of duties of care arising out of tort law.” Baker v. McCollan, 443 U.S. 137, 146, 99 S.Ct. 2689, 2695, 61 L.Ed.2d 433, 443 (1979). To state a cause of action under § 1983 for violation of the Due Process Clause, plaintiffs “must show that they have asserted a recognized ‘liberty or property5 interest within the purview of the Fourteenth Amendment, and that they were intentionally or recklessly deprived of that interest, even temporarily, under color of state law.” Griffith v. Johnston, 899 F.2d 1427, 1435 (5th Cir.1990) (citations omitted), cert. denied, 498 U.S. 1040, 111 S.Ct. 712, 112 L.Ed.2d 701 (1991). “The Supreme Court has expanded the definition of ‘liberty’ beyond the core textual meaning of that term to include [not only] the ... privileges [expressly] enumerated by the Bill of Rights, [but also] the ‘fundamental rights implicit in the concept of ordered liberty’ and ‘deeply rooted in this Nation’s history and tradition’ under the Due Process Clause.” Id.; see also Bowers v. Hardwick, 478 U.S. 186, 191, 106 S.Ct. 2841, 2844, 92 L.Ed.2d 140, 146 (1986); Hewitt v. Helms, 459 U.S. 460, 466, 103 S.Ct. 864, 869, 74 L.Ed.2d 675, 684-85 (1983); Moore v. City of East Cleveland, 431 U.S. 494, 503, 97 S.Ct. 1932, 1937, 52 L.Ed.2d 531, 539-40 (1977).
The Due Process Clause of the Fourteenth Amendment provides that no state shall “deprive a person of life, liberty or property without due process of law.” The Supreme Court has noted: “Although a literal reading of the Clause might suggest that it governs only the procedures by which a State may deprive persons of liberty, for at least 105 years, at least since Mugler v. Kansas, 123 U.S. 623, 8 S.Ct. 273, 31 L.Ed. 205 [in 1887], the Clause has been understood to contain a substantive component as well....” Planned Parenthood v. Casey, -U.S. -, -, 112 S.Ct. 2791, 2804, 120 L.Ed.2d 674, 695 (1992) (citation omitted). This substantive component of the Due Process Clause “protects individual liberty against ‘certain government actions regardless of the fairness of the procedures used to implement them.’ ” Collins v. City of Hark-er Heights, — U.S. -, -, 112 S.Ct. 1061, 1068, 117 L.Ed.2d 261, 273 (1992) (quoting Daniels v. Williams, 474 U.S. 327, 331, 106 S.Ct. 662, 665, 88 L.Ed.2d 662, 668 (1986)).
Jane Doe’s substantive due process claim is grounded upon the premise that schoolchildren have a liberty interest in their bodily integrity that is protected by the Due Process Clause of the Fourteenth Amendment and upon the premise that physical sexual abuse by a school employee violates that right. This circuit held as early as 1981 that “[t]he right to be free of state-occasioned damage to a person’s bodily integrity is protected by the fourteenth amendment guaran[451]*451tee of due process.” Shillingford v. Holmes, 634 F.2d 263, 265 (5th Cir.1981). Shilling-ford involved a § 1983 action by a tourist against a New Orleans police officer. Shil-lingford was attending Mardi Gras festivities in New Orleans when he attempted to take a photograph of the officer making an arrest. The officer was annoyed and struck Shilling-ford with his nightstick, inflicting some physical injury. We found such action sufficient “to transcend the bounds of ordinary tort law and establish a deprivation of constitutional rights.” Id. at 266.
We cited Shillingford for this principle of law in Jefferson v. Ysleta Independent School District, 817 F.2d 303, 305 (5th Cir.1987), a case involving a violation of a schoolchild’s substantive due process rights by a teacher. The teacher in Jefferson lashed a second grade student to a chair for the better part of two school days. Again, we found that such actions by the teacher violated the student’s substantive due process “ ‘right to be free of state-occasioned damage to [her] bodily integrity.’ ” Id. (quoting Shillingford, 634 F.2d at 265). We have also held that the infliction of “corporal punishment in public schools ‘is a deprivation of substantive due process when it is arbitrary, capricious, or wholly unrelated to the legitimate state goal of maintaining an atmosphere conducive to learning.’” Fee v. Herndon, 900 F.2d 804, 808 (5th Cir.) (quoting Woodard v. Los Fres-nos Indep. Sch. Dist., 732 F.2d 1243, 1246 (5th Cir.1984)), cert. denied, 498 U.S. 908, 111 S.Ct. 279, 112 L.Ed.2d 233 (1990).
If the Constitution protects a schoolchild against being tied to a chair or against arbitrary paddlings, then surely the Constitution protects a schoolchild from physical sexual abuse — here, sexually fondling a 15-year old school girl and statutory rape — by a public schoolteacher. Stroud’s sexual abuse of Jane Doe, earlier detailed in this opinion, is not contested by the defendants. Thus, Jane Doe clearly was deprived of a liberty interest recognized under the substantive due process component of the Fourteenth Amendment.3 It is incontrovertible that bodily integrity is necessarily violated when a state actor sexually abuses a schoolchild and that such misconduct de[452]*452prives the child of rights vouchsafed by the Fourteenth Amendment.4 Obviously, there is never any justification for sexually molesting a schoolchild, and thus, no state interest, analogous to the punitive and disciplinary objectives attendant to corporal punishment, which might support it.5
B
Having concluded that Stroud’s physical sexual abuse of Jane Doe violated her constitutional right to substantive due process, we next must decide whether school officials, like the appellants in this case, owe any duty to a schoolchild when a subordinate violates that child’s constitutional rights. Section 1983 provides a claim against anyone who, “under color of’ state law, deprives another of his or her constitutional rights. 42 U.S.C. § 1983; see, e.g., Collins v. City of Harker Heights, — U.S. -, -, 112 S.Ct. 1061, 1066, 117 L.Ed.2d 261, 270 (1992).
In Monell v. New York City Department of Social Services, 436 U.S. 658, 691-94, 98 S.Ct. 2018, 2037-38, 56 L.Ed.2d 611, 635-38 (1978), the Supreme Court held that Congress intended § 1983 to apply to local gov-emment entities as well as to persons. The Court1, however, also held that local governments cannot be held liable under § 1983 on a respondeat superior theory. Similarly, we have held that supervisory officials may not be found vicariously liable for the actions of their subordinates under § 1983.6 Lopez v. Houston Indep. Sch. Dist., 817 F.2d 351, 355 (5th Cir.1987) (citing Thibodeaux v. Arceneaux, 768 F.2d 737, 739 (5th Cir.1985)).
This circuit has held that supervisors can be liable for “gross negligence” or “deliberate indifference” to violations of their subordinates. In Hinshaw v. Doffer, 785 F.2d 1260, 1262 (5th Cir.1986), Hinshaw sued both the police chief and his deputy for the deputy’s excessive use of force in arresting Hin-shaw, who had come to the police station to investigate a report that the police had arrested and roughed up his son. We established a three-part test for supervisory liability in which, “the plaintiff must show that: 1) the police chief failed to supervise or train the officer, 2) a causal connection existed between the failure to supervise or train and the violation of the plaintiffs rights, and 3) such failure to supervise or train amounted [453]*453to gross negligence or deliberate indifference.” Id. at 1263.
In Lopez, we applied these same principles when we adopted a narrow duty on the part of school officials: a duty not to “callously disregard” a student’s constitutional rights. Id. 817 F.2d at 355. The Lopez panel, throughout its opinion, interchangeably used the terms “callous disregard,” “deliberately indifferent,” “grossly negligent,” and “callous indifference.” In addition, in a case involving a municipality’s alleged failure to train its employees, the Supreme Court rejected the gross negligence standard of liability in favor of the stricter7 deliberate indifference standard. City of Canton v. Harris, 489 U.S. 378, 381, 388, 109 S.Ct. 1197, 1200-01, 1204, 103 L.Ed.2d 412, 421-22, 426 (1989). The Court’s reasoning in assessing a municipality’s liability leads us to use the same standard in assessing an individual supervisor’s liability under § 1983.
In Canton, the Supreme Court held that a municipality is responsible in certain circumstances under § 1983 for a failure to train its employees that results in the violation of a plaintiff’s right to receive necessary medical attention while in police custody. Id. The Court explained, however, that such liability, predicated on a violation of the plaintiffs right under the Due Process Clause of the Fourteenth Amendment, depends on a showing of (1) a “deliberately indifferent” policy of training that (2) was the “closely related” cause of the violation of the plaintiffs federally protected rights. Id. at 388, 391, 109 S.Ct. at 1204, 1206, 103 L.Ed.2d at 426, 428. The Court explained that “to adopt lesser standards of fault and causation” would result in de facto respondeat superior liability for municipalities:
In virtually every instance where a person has had his or her constitutional rights violated by a city employee, a § 1983 plaintiff will be able to point to something the city ‘could have done’ to prevent the unfortunate incident. Thus, permitting cases against cities for their ‘failure to train’ employees to go forward under § 1983 on a lesser standard of fault would result in de facto respondeat superior liability on municipalities — a result we rejected in Mo-nell.
Id. at 392, 109 S.Ct. at 1206, 103 L.Ed.2d at 428 (citation omitted). The Court further explained that lesser standards of fault and causation would require the federal courts endlessly to “second-guess” the wisdom of municipal training programs, a task inappropriate for the federal judiciary. Id. One commentator has suggested a third reason for the Court’s holding: “[0]nly when training deficiencies are the result of deliberate indifference will the trier of fact be able to conclude that inadequate training was the actual or ‘closely related’ cause of the violation of the plaintiffs federal rights.” Martin A. Schwartz & John E. Kirklin, 1 Section 1983 Litigation: Claims, Defenses, and Fees § 7.9, at 372 (2d ed. 1991).
The most important difference between City of Canton and this case is that the former dealt with a municipality’s liability whereas the latter deals with an individual supervisor’s liability. The legal elements of an individual’s supervisory liability and a political subdivision’s liability, however, are similar enough that the same standards of fault and causation should govern. A municipality, with its broad obligation to supervise all of its employees, is liable under § 1983 if it supervises its employees in a manner that manifests deliberate indifference to the constitutional rights of citizens. We see no principled reason why an individual to whom the municipality has delegated responsibility to directly supervise the employee should not be held hable under the same standard. Other circuits have reached substantially the same result. See Sample v. Diecks, 885 F.2d 1099, 1117-18 (3d Cir.1989) (“Although the issue here is one of individual liability rather than of the liability of a political subdivision, we are confident that, absent official immunity, the standard of individual liability for [454]*454supervisory public officials will be found to be no less stringent than the standard of liability for the public entities that they serve.” (footnote omitted)); Greason v. Kemp, 891 F.2d 829, 837 (11th Cir.1990); Stoneking v. Bradford Area Sch. Dist., 882 F.2d 720, 725 (3d Cir.1989) (Stoneking II), cert. denied, 493 U.S. 1044, 110 S.Ct. 840, 107 L.Ed.2d 835 (1990); Jane Doe “A” v. Special Sch. Dist., 901 F.2d 642 (8th Cir.1990).
There are other differences between Canton and this case. For example, City of Canton involved a different kind of supervisory liability, failure to train, from that involved here. Moreover, the plaintiff in City of Canton alleged a violation of her substantive due process right to receive medical attention whereas the plaintiff in this case alleges a violation of her substantive due process right to be free from sexual abuse. The similarities between the cases, however, are more important than the differences: Both eases involve alleged failures of supervisors to prevent substantive due process violations occasioned by their subordinates.8 Thus, in Gonzalez v. Ysleta Independent School District, 996 F.2d 745, 753-60 (5th Cir.1993), we applied City of Canton to an elementary school student’s § 1983 claim against a school district for supervisory failures that led to a teacher’s violation of her substantive due process right to bodily security.9 We concluded that the school district could be held liable for supervisory failures resulting in the molestation of the student only if those failures “manifested a deliberate indifference to the welfare of the school children.” Id. 996 F.2d at 760. We therefore hold that a school official’s liability arises only at the point when the student shows that the official, by action or inaction, demonstrates a deliberate indifference to his or her constitutional rights.
Using this standard, we adopt the following test, which determines the personal liability of school officials in physical sexual abuse cases. A supervisory school official can be held personally liable for a subordinate’s violation of an elementary or secondary school. student’s constitutional right to bodily integrity in physical sexual abuse cases if the plaintiff establishes that:
(1) the defendant learned of facts or a pattern of inappropriate sexual behavior by a subordinate pointing plainly toward the conclusion that the subordinate was sexually abusing the student; and
(2) the defendant demonstrated deliberate indifference toward the constitutional rights of the student by failing to take action that was obviously necessary to prevent or stop the abuse; and
(3) such failure caused a constitutional injury to the student.
C
We must next consider these legal principles in the context of qualified immunity. Under the shield of qualified immunity, Caplinger and Lankford cannot be held liable under § 1983 unless (1) Jane Doe’s liberty interest under the substantive due process component of the Fourteenth Amendment, and (2) Caplinger’s and Lank-ford’s duty with respect to Jane Doe’s constitutional right were “clearly established” at the time these events took place. See Stem v. Ahearn, 908 F.2d 1, 5 (5th Cir.1990), cert. denied, 498 U.S. 1069, 111 S.Ct. 788, 112 L.Ed.2d 850 (1991). For a constitutional right to be clearly established, “[t]he con[455]*455tours of the right must be sufficiently clear that a reasonable official would understand that what he is doing violates that right.” Anderson v. Creighton, 483 U.S. 635, 640, 107 S.Ct. 3034, 3039, 97 L.Ed.2d 523, 531 (1987). The term “clearly established” does not necessarily refer to “commanding precedent” that is “factually on all-fours with the case at bar,” or that holds the “very action in question” unlawful. Jefferson, 817 F.2d at 305 (footnote omitted); Anderson, 483 U.S. at 640, 107 S.Ct. at 3039, 97 L.Ed.2d at 531. Rather, a constitutional right is clearly established if “in the light of pre-existing law the unlawfulness [is] apparent.” Anderson, 483 U.S. at 640, 107 S.Ct. at 3039, 97 L.Ed.2d at 531. Put another way, officials must observe “general, well-developed legal principles.” Jefferson, 817 F.2d at 305.
Lankford and Caplinger argue, first, that the underlying constitutional right, to be free of sexual abuse, was not clearly established in 1987. Second, they assert that even if the underlying constitutional right was clearly established in 1987, their duty under § 1983 not to be deliberately indifferent to a subordinate’s violation of that right was not clearly established.
The “contours” of a student’s substantive due process right to be free from sexual abuse and violations of her bodily integrity were clearly established in 1987. In 1987 this court held that it was clearly established in 1985 that the Due Process Clause protects a schoolchild from being lashed to a chair for the better part of two days for “instructional purposes.” Jefferson, 817 F.2d at 305. As the panel in this ease noted, Judge Posner has observed:
There has never been a section 1983 case accusing welfare officials of selling foster children into slavery; it does not follow that if such a case arose, the officials would be immune from damages liability....
K.H. ex rel. Murphy v. Morgan, 914 F.2d 846, 851 (7th Cir.1990). This case involves similarly egregious and outrageous conduct. Indeed, this much seems crystal clear: No reasonable public school official in 1987 would have assumed that he could, with constitutional immunity, sexually molest a minor student.10
Not only was the underlying violation clearly established in 1987, but Lankford’s and Caplinger’s duty with respect to that violation was also clearly established at that time. In Lopez, a student who was knocked unconscious during a fight on a school bus sued the bus driver’s supervisors under § 1983, alleging that the supervisors’ failure to properly train the driver resulted in the driver’s failure to break up the melee and render medical assistance. 817 F.2d at 353, 355. In that case, we held that the supervisors could be found liable if they “callously disregarded,” or were “grossly negligent” to, the student’s right to bodily integrity and if their failure to train resulted in the violation of that right. Id. at 355. Our eases before Lopez, although arising under somewhat different circumstances, also acknowledged a duty on the part of supervisors not to be grossly negligent or deliberately indifferent to constitutional violations perpetrated by their subordinates. For example, in Wanger v. Bonner, 621 F.2d 675 (5th Cir.1980), we upheld a trial court’s instruction that a sheriff could be liable for his deputies’ activities even though he did not participate in them, “if you find that he failed to adequately su[456]*456pervise or train his deputies, thus causing a violation of plaintiffs’ civil rights.” Id. at 680. In Bowen v. Watkins, 669 F.2d 979, 988 (5th Cir.1982), we observed generally that:
Although supervisory officials cannot be held liable solely on the basis of their employer-employee relationship with a tortfeasor, they may be liable when their own action or inaction, including a failure to supervise that amounts to gross negligence or deliberate indifference, is a proximate cause of the constitutional violation.
We also held that a municipality’s supervisory liability for a police officer’s violation of a citizen’s constitutional rights depended on a showing that, among other things, the municipality displayed “gross negligence amounting to conscious indifference.” Languirand v. Hayden, 717 F.2d 220, 227 (5th Cir.1983), cert. denied, 467 U.S. 1215, 104 S.Ct. 2656, 81 L.Ed.2d 363 (1984); see also Hinshaw v. Doffer, 785 F.2d 1260 (5th Cir.1986).
In the face of this precedent, Lank-ford and Caplinger point to no authority from this circuit involving school officials which would enable them to reasonably believe, in 1987, that they could be deliberately indifferent to their subordinate’s violation of a student’s constitutional rights and escape supervisory liability under § 1983. In fact, Lopez and our earlier cases arguably announced a broader duty on the part of school officials than we adopt today. See Lopez, 817 F.2d at 355. By narrowing the duty that § 1983 imposes on supervisors, the courts have not affected its status as “clearly established.”
D
Having established that Jane Doe’s constitutional right to bodily integrity and the appellants’ duty with respect to that right were clearly established in 1987 when these events occurred, we must determine whether, on the record before us, Lankford and Caplinger have established that they satisfied then-duty to Doe, and are thus entitled to summary judgment as a matter of law.11
The plaintiff in this case has adduced clear summary judgment evidence of deliberate indifference by defendant Lank-ford toward her constitutional rights.12 By 1987, Lankford had certainly received notice of a pattern of inappropriate behavior that had been committed by Stroud that suggested misconduct of a sexual nature. He had spoken with Stroud two years earlier, in 1985, about being “too friendly” with a particular female student. He had received complaints from parents about Stroud’s favoritism toward certain girls in the classroom. The school librarian reported Stroud’s inappropriate behavior with female students to Lankford on two occasions, and at one point described the incident she witnessed as “child molestation.” More impor[457]*457tantly, Lankford received knowledge that Stroud was directing his inappropriate sexual behavior specifically toward Doe. He had heard about Mickey Miller’s report of Stroud’s misconduct with freshman girls, including Jane Doe, at a school basketball game. A jury could find that Lankford then received a clear signal that Stroud and Doe were engaged in a sexual relationship when Brittani B. gave him the valentine in February 1987. Later that year, Lankford received reports about Stroud’s inappropriate behavior with Doe at the Com Festival and learned that Doe’s parents had discovered Stroud’s autographed photographs in Doe’s possession. Thus, under the facts construed in the light most favorable to Jane Doe and considering all the information Lankford received about Stroud’s relationship with Doe, she has satisfied the first prong of the test with respect to defendant Lankford — knowledge of facts or a pattern of inappropriate sexual behavior by Stroud pointing plainly toward the conclusion that he was sexually abusing Doe.
Doe has also illustrated, in a manner sufficient to survive a summary judgment motion, that Lankford demonstrated deliberate indifference to the offensive acts by failing to take action that was obviously necessary to prevent or stop Stroud’s abuse. When certain parents complained about Stroud’s favoritism, Lankford suggested that their children were “jealous” of the favorite students. Lankford similarly dismissed the librarian’s report of “child molestation.” In perhaps the most striking example of his apathy, he responded to Brittani B.’s presentation of the valentine — which he admitted appeared to bear Stroud’s handwriting — by transferring Brittani (not Jane Doe) out of Stroud’s class. He never bothered to discuss the valentine incident with Caplinger, Stroud, Doe, or Doe’s parents. He did not record any of these complaints of inappropriate conduct in Stroud’s personnel file. He did not take the obvious steps of removing Doe from Stroud’s class and directing Stroud to stay away from Doe. Both Stroud and Doe stated that they did not begin having sexual intercourse until late March or early April 1987. A jury could reasonably conclude that had Lankford taken actions that were obviously necessary in response to the valentine — indeed, if he had responded at all — the relationship might have been derailed at that point and the violation of Jane Doe’s rights would not have been as severe or prolonged. Thus, Jane Doe has, in a manner sufficient to withstand a motion for summary judgment, stated a claim under § 1983 that defendant Lankford was deliberately indifferent to his subordinate’s violation of her constitutional right to bodily integrity.13
With respect to whether defendant Ca-plinger is immune from this lawsuit, however, the evidence presented tells a different story. The first time Caplinger heard of any potential misconduct by Stroud was when he received the report from Mickey Miller in February 1987. He promptly notified Lank-ford and instructed him to speak with Stroud about the incident. There is no evidence that Lankford informed Caplinger at that time about Stroud’s past behavior, and it is undisputed that Lankford never documented any of the reports he had received about Stroud.
Caplinger did not receive any other reports about Stroud until June 1987, when two parents reported the Corn Festival incident to him. Again, Caplinger promptly responded by contacting the parents of one of the allegedly misbehaving students reportedly at the festival. He was assured that the accused student was not even at the event. We cannot say that Caplinger’s decision not to pursue the investigation further, after the parents assured him that their child had not even attended the Com Festival, exhibited deliberate indifference.
[458]*458When Doe’s parents met with Caplinger concerning the photographs of Stroud in July 1987, Caplinger again responded appropriately, if ineffectively, to the situation. He met with Jane Doe privately and questioned her about her relationship with Stroud. He also met with Stroud, verbally reprimanded him about the inappropriate comments on the photographs, warned him to keep his distance from Jane Doe, and informed him of the consequences if the misconduct continued.
Although after the July photograph incident Caplinger had received notice of a pattern of inappropriate sexual behavior sufficient to satisfy the first prong of the test, he certainly did not respond to the misconduct with deliberate indifference. He instructed Lankford to speak with Stroud about the incident at the basketball game; he personally investigated the report concerning the Corn Festival report; and he met with Stroud immediately after learning of the photographs, reprimanded him for his conduct, and unequivocally warned him of the consequences if any further misconduct was reported. His actions were ineffective, but not deliberately indifferent. Summary judgment should have been granted to defendant Caplinger on the grounds of qualified immunity.
IV
EQUAL PROTECTION
The plaintiff also asserts that Stroud’s behavior toward her violated her constitutional rights under the Equal Protection Clause of the Fourteenth Amendment. Doe advances three separate equal protection theories, based on two different sorts of behavior. She first argues that the physical sexual abuse to which Stroud subjected her constituted sexual harassment, which she argues is offensive to the Equal Protection Clause. Second, she contends that Stroud’s classroom favoritism toward her also constituted sexual harassment. Finally, she argues that the classroom favoritism constituted the more typical form of disparate gender discrimination, which the Supreme Court has found to be prohibited by the Equal Protection Clause. Following these theories, Doe argues that Caplinger and Lankford should be liable because, as in the ease of her due process claim, they were deliberately indifferent to the unconstitutional conduct that caused her injury.
Assuming that Stroud sexually abused Doe, which the defendants do not contest, Stroud violated Doe’s substantive due process rights as a matter of law. Doe does not claim that the damages that she could recover from Lankford based on Stroud’s alleged violation of her equal protection rights would be any more extensive than the damages that she could recover based on the substantive due process violation. Nor does she argue that, or show how, Caplinger could be super-visorily liable for equal protection violations predicated on Stroud’s sexual abuse when he is not supervisorily liable for substantive due process violations involving the same conduct. Consequently, we need not reach the question of whether Doe states an equal protection claim.
V
The sole question before us is the propriety of the district court’s denial of qualified immunity to the appellant school officials. The school officials’ main argument that the liability of a school official for ignoring a subordinate’s sexual abuse of a 15-year old student was not clearly established in 1987.
Appellants, however, agree that by 1987 the Constitution clearly protected the most hardened criminal inmate from abuse by his guard and imposed liability on the guard’s supervisor who was consciously indifferent to such abuse. Similarly, appellants cannot seriously contest that the § 1983 liability of a police chief was not clearly established in 1987 when the chief was consciously indifferent to his officer’s physical abuse of a citizen. In short, supervisory liability for deliberate indifference to constitutional violations committed by subordinates was clearly established when the events in this case occurred. Consequently, the school officials’ argument that with constitutional immunity they could ignore the teacher/eoach’s physical sexual abuse of an impressionable 15-year old student is, as a practical matter perverse, and, [459]*459as a legal matter, not supported by the case law. Such an argument neither legally nor logically mates any sense.
For the reasons stated above, we affirm the district court’s order denying qualified immunity to defendant Lankford and reverse the district court’s order denying qualified immunity to defendant Caplinger. We also remand this case to the district court for further proceedings consistent with this opinion.
AFFIRMED in part, REVERSED in part and REMANDED.