In "Franklin v. Gwinnett County Public Schools" (1992), the U.S. Supreme Court held that private citizens could collect damage awards when teachers sexually harassed their students. In "Bethel School District No. 403 v. Fraser" (1986) the courts ruled that schools have the power to discipline students if they use "obscene, profane language or gestures" which could be viewed as substantially interfering with the educational process, and inconsistent with the "fundamental values of public school education." Under regulations issued in 1997 by the U.S. Department of Education, which administers Title IX, school districts should be held responsible for harassment by educators if the harasser "was aided in carrying out the sexual harassment of students by his or her position of authority with the institution." In "Davis v. Monroe County Board of Education", and "Murrell v. School Dist. No. 1", 1999, schools were assigned liability for peer-to-peer sexual harassment if the plaintiff sufficiently demonstrated that the administration's response shows "deliberate indifference" to "actual knowledge" of discrimination.