of Title VI are coextensive with those available under the ADA and the RA, Barnes v. Gorman, 536 U.S. 181, 185, 122 S.Ct. 2097, 2100, 153 L.Ed.2d 230 (2002). Other courts of appeals to have considered the issue agree that deliberate indifference may, in certain circumstances, establish intentional discrimination for the purposes of a Title VI claim. See, e.g., Zeno v. Pine Plains Cent. Sch. Dist., 702 F.3d 655, 664-65 (2d Cir.2012) (explaining that deliberate indifference to teacher or peer harassment of individual may create liability if a plaintiff establishes “(1) substantial control, (2) severe and discriminatory harassment, (3) actual knowledge, and (4) deliberate indifference”); Bryant v. Indep. Sch. Dist. No. 1-38 of Garvin Cnty., Ok., 334 F.3d 928, 934 (10th Cir.2003) (<HOLDING>); Monteiro v. Tempe Union High Sch. Dist., 158
holding that deliberate indifference to known instances of studentonstudent racial harassment is a viable theory in a title vi intentional discrimination suit holding that racial discrimination is a personal injury tort holding that such a theory is viable under title vii holding that because the proper defendant in a title vi case is an entity rather than an individual plaintiff could not be sued in his individual capacity under title vi holding plaintiffs bringing claims under the ada may establish intentional discrimination with a showing of deliberate indifference