Gebser v. Lago Vista Independent School District (1998) established the legal standards under which school boards that receive federal funds can be liable for damages for teacher-to-student sexual harassment under Title IX of the Education Amendments of 1972. Gebser is one of the Supreme Court's three rulings on sexual harassment in schools and was the second to address teacher-to-student harassment. The Court's other case involving sexual harassment by a teacher of a student was Franklin v. Gwinnett County Public Schools (1992). The Court's final case on the topic, Davis v. Monroe County Board of Education (1999), addressed student-to-student sexual harassment.