WINFIELD – A former student says a former Buffalo High School teacher groomed her and sexually assaulted her.
The plaintiff, identified only as Jane Doe, filed her complaint in Putnam Circuit Court against Jay Roudebush and the Putnam County Board of Education.
According to the complaint, the plaintiff was a student at Buffalo High in the fall of 2021 and was in a sociology class taught by Roudebush, who lives in Hurricane. It was his first year teaching at Buffalo, and the plaintiff says she didn’t know him before that.
Before being transferred to Buffalo, Roudebush had initiated or engaged in inappropriate conduct with students at one or more Putnam County schools, according to the complaint. It also says the board knew of these allegations but took no corrective or disciplinary action or even an investigation, the complaint states.
“Roudebush began to implement his predatory plan to groom, lure and entice female students into having a sexual relationship with him,” the complaint states. “Roudebush made false claims about himself so that students would trust him.”
It says he bragged that he was independently wealthy, a successful businessman and had owned an expensive sports car but bought a Blazer to blend in. He claimed he didn’t need to work but taught only because he cared so much about students. He also offered to buy female students expensive gifts, according to the complaint.
“Roudebush loved telling his classes how smart he was and bragged that he had earned multiple college and post-graduate degrees,” the complaint continues. “In order to perpetuate the falsehood that he was an adult who could be trusted, defendant Roudebush tried to villainize his students’ parents and make them believe that their parents were their enemies.”
He told students to get an app for their phones called Signal because “it would let them send any type of pictures and videos, and let them have private conversations with anyone, all without their parents being able to see any of it.”
Roudebush also spoke openly about his open marriage, according to the complaint, and encouraged students to ask personal questions about it. He also told students it was acceptable to have multiple sexual partners.
“A dog has to eat when he’s hungry,” Roudebush said, according to the complaint.
When Roudebush’s “predatory scheme” was working, the complaint says he fostered a false sense of trust in students and began to target specific female students by initiating private conversations with them so he could speak to them more intimately and suggestively. One of them was the plaintiff.
“In order to prey on her teenage vulnerabilities, he told plaintiff how pretty, smart and good she was, and repeatedly made unsolicited offers to help plaintiff with her school assignments and homework for both his class and for other classes,” the complaint states. “Though plaintiff was a straight-A student, defendant Roudebush told her that she didn’t need to do her assignments or even take her tests, telling her to just write anything down so that it at least looked to everyone else she had done the work.
“No matter what she scribbled and doodled on assigments and tests, defendant always gave her a 100%.”
When her scribbles included random facts about herself or things she liked, she says Roudebush would write follow-up questions seeking more detail.
“This was the equivalent of a teacher passing private notes back and forth to a minor student in order to learn more personal and intimate details about her,” the complaint states.
The plaintiff says Roudebush offered and wrote essays for her online college-level English class, and he offered her his personal jacket to wear in and out of class.
When he learned the plaintiff played Words With Friends on her phone, the complaint says Roudebush downloaded the app and sent a private request to her to play a game with him.
“After they started playing each other, defendant Roudebush began to send plaintiff personal and sexually suggestive private messages,” the complaint alleges. “One morning, plaintiff saw defendant Roudebush openly and obviously ogling her as she walked to another class, and within minutes sent her a Words With Friends message containing three fire emojis to tell her that he thought she looked ‘hot.’”
Soon, the plaintiff says Roudebush began physically touching her. It started by him putting his hand on her shoulder or waist, then he would graze his leg against hers when he sat down next to her.
“Roudebush then began to create situations where he could be alone with plaintiff at school,” the complaint states. “Roudebush would message plaintiff and tell her to lie to her teacher that she needed to go to the bathroom just so that she could get out of her class and meet defendant in his empty classroom.
“Roudebush created these private encounters as part of his grooming scheme in order to isolate plaintiff and in order to perpetrate physical and sexual contact on her.”
When he convinced the plaintiff to download the Signal app, Roudebush began sending her sexully explicit messages on that app, according to the complaint. His messages there included multiple sexual scenarios describing in explicit detail what they would be doing to each other.
“I want you,” one message said, according to the complaint. “I want to f--k you so bad. … take your clothes off and get under your covers.”
Other messages are more graphic. Roudebush also told the plaintiff he loved her in those messages, according to the complaint.
During a class change, Roudebush invited the plaintiff into his empty classroom and took her into a corner where they couldn’t be seen, and he kissed her, according to the complaint.
During the semester, Roudebush continued to encourage the plaintiff to come to his room during his planning periods, according to the complaint, and he began to kiss, touch and fondle her. He eventually became more aggressive and thrust his hand inside her panties and touched her vagina, according to the complaint.
Roudebush even asked the plaintiff about allowing his wife to join their physical encounters, which she declined.
The plaintiff also claims Roudebush used emotional manipulation to keep her silent, and she says he made implied threats of violence.
The plaintiff says all of the sexual acts Roudebush committed took place on school property while school was in session, according to the complaint. Other teachers and administrators saw Roudebush’s inappropriate conduct and suspected something was up, according to the complaint.
“Roudebush told plaintiff that he had been confronted by at least two teachers and one vice principal after witnessing his interactions with plaintiff,” the complaint states. “Roudebush told plaintiff that the vice principal even called him into his office to question him about what he had witnessed.
“In response, defendant Roudebush vehemently denied the allegations and told him, ‘If you think I’m a pedophile, then fire me!,’ and implicit threat that worked and silenced the vice principal.”
Still, no action was taken against Roudebush, and the school board never bothered to investigate until a non-employee of the board expressed concern about his relationship with the plaintiff. But, a board employee gave Roudebush advance warning about that investigation, giving him time to destroy evidence and intimidate plaintiff to lie, according to the complaint.
On December 6, 2021, Roudebush send the plaintiff a message on Signal to tell her the county school superintendent was going to interview him about the situation, according to the complaint. He ordered the plaintiff to delete the Signal app from her phone and gave her instructions on how to do so.
“Roudebush warned her that she should ‘protect him’ and never say anything about their relationship to anyone,” the complaint states.
The complaint also says the board allowed Roudebush to continue to teach during the investigation and didn’t even remove the plaintiff from his class.
On December 16, 2021, a petition was filed in court to prevent Roudebush from having personal contact with the plaintiff for two years. Several days after the investigation began, the school board placed Roudebush on administrative leave.
Roudebush “voluntarily terminated his employment with the defendant Board before the investigation was completed, a choice he apparently made to avoid his inevitable firing,” the complaint states.
As a result of Roudebush’s actions, the plaintiff says she suffers from emotional distress, mental health problems such as depression and anxiety. She says she has panic attacks, sleeplessness, nightmares and suicidal thoughts. She also says she was diagnosed with PTSD.
She accuses Roudebush of civil assault and civil battery, and she accuses the board of failure to provide a safe and secure school environment, negligence and negligent hiring, training, supervision and retention. She accuses both defendants of breach of fiduciary duties.
She seeks joint and several compensatory damages for pain and suffering, loss of enjoyment of life, medical expenses, loss of earning capacity, lost future earnings, humiliation and embarrassment. She also seeks joint and several punitive damages.
The board has filed a motion for dismissal from the case, and Roudebush also has filed an answer denying the allegations and seeking to have the case dismissed.
The plaintiff is being represented by Richard E. Holtzapfel of Holtzapfel Law Offices in Hurricane. Roudebush is being represented by Julie Greco of Pullin Fowler Flanagan Brown & Poe in Charleston, and the board is being represented by David Mincer of Bailey & Wyant in Charleston.
Putnam Circuit Court case number 23-C-70