In the wake of Columbine and other high-profile school shootings, educators and the public at large have become increasingly aware of the danger and damage that bullying can cause. For example, a study by the U.S. Secret Service suggests that bullying was a contributing factor in two-thirds of 37 school shooting episodes. Other recent research reveals a significant relationship between weapons and not only bullies but targets of bullying, noting that many bullies started as victims. Given such findings, it is not at all surprising that researchers recommend that schools make anti-bullying part of their mission. Going further, approximately a dozen states, led by Colorado, have adopted legislation requiring public schools to adopt anti-bullying policies. Bullying-related litigation is also on the rise. The theories of liability range from state common law claims, such as negligence, to federal civil rights claims, such as racial harassment. Moreover, in some cases, the perpetrator and/ or the victim may be a student with a disability. The accompanying case and question-and-answer discussion illustrate recent trends with regard to outcomes of these varying claims for liability. The Case 5 In 1996, after 24 years of experience as an educator, Karen Siris became principal of W. S. Boardman Elementary School in the Oceanside Union Free School District, which is on Long Island, New York. Author of a doctoral dissertation entitled "Using Teacher Action Research to Alleviate Bullying and Victimization in Schools," she instituted an "antibullying" philosophy at Boardman that included classroom presentations at the start of each school year, written materials to the teachers, and a motivational film for the entire school, with follow-up teacher activities.