YOUNGSTOWN The family suing Ursuline High School and the Catholic Diocese of Youngstown over alleged hazing and misconduct has filed an amended federal complaint, which was later subject to a correction, clarifying the identities of several student defendants and adding an athletic department official as a potential defendant.

The corrected complaint, filed in U.S. District Court, updates the original filing regarding incidents alleged to have occurred during a school-sanctioned football camp trip in June 2025. The lawsuit maintains its core allegations, including civil-rights violations, civil liability for criminal acts like hazing and distributing child pornography, and state-law claims for negligent and reckless supervision and retention. The lawsuit against Ursuline High School and the Catholic Diocese of Youngstown is known as Jane Doe, et al. v. Ursuline High School.

The filing was submitted after the court ordered a correction, with the plaintiffs requesting an extension of time to comply with that order.

The amended complaint states that the plaintiffs' attorneys intend to add Ursuline athletic director and teacher, John DeSantis, as a defendant if they discover information about DeSantis's alleged level of involvement.

The original complaint had listed the school, the Diocese, Principal Matthew Sammartino, Assistant Principal Margaret Damore, Head Football Coach Daniel Reardon, and two assistant coaches, Timothy McGlynn and Christian Syrianoudis.

The allegations concerning DeSantis focus on his actions following the alleged hazing incidents. The document claims DeSantis was present when Principal Sammartino and Assistant Principal Damore addressed the players identified as assailants. The filing states that the coaches and administrators told the players that "an investigation into the matter was ongoing and instructed them not to talk to anyone about what happened." The complaint, however, notes that currently available evidence does not suggest DeSantis was complicit in the warning and instruction.

One of the initial differences in the amended filing is the revision of the pseudonyms used by the plaintiffs to protect their identities. The original complaint identified the mother and her two minor children as Mother King, Son King, and Daughter King, respectively. The amended document replaces the "King" pseudonyms with "Doe" pseudonyms, referring to the family as Jane Doe, Son Doe, and Daughter Doe.

The amended complaint identifies several student defendants who were listed using generic pseudonyms and placeholders in the original filing, replacing "[FNU]" (First Name Unknown) parent designations with full names and clarified relationships.

A Notice of Errata, filed October 24, 2025, further corrected information regarding one of the student defendants.

The initial filing had identified one student defendant as Ursuline Player-4. The amended complaint identified the student as Ta.W. and their guardians as Gerald Wilson and Rita Wilson.

The subsequent Notice of Errata filed by the plaintiffs' attorneys on October 24, 2025, stated that the more accurate guardian information for Ta.W. is Raylette Robinson, the grandparent and guardian of the minor child. The notice asked the court clerk to correct the records accordingly.

Other student defendants' pseudonyms were replaced with initials: Ursuline Player-1 became D.P., Player-5 became C.C., Player-8 became To.W., and Player-9 became D.T., among others. The parents of player D.T. in the amended complaint are now identified as Somer Thomas and an unnamed Wilson.

The amended complaint also includes a detail linking one student defendant, T.S., with one of the defendant coaches. The parents of Player T.S. are listed as Charlotte Syrianoudis and an unnamed Syrianoudis. The updated address for the student and family in the amended complaint, South Hillside Drive, is the same residential address listed for assistant coach Christian Syrianoudis.

The complaint alleges that the high school's actions, and the actions of its administrators, coaches, and students, violated the school's stated values. The lawsuit claims that the school's culture, in part due to the alleged negligent hiring, training, and retention of coaches, prioritized the football team's "glory" over the safety of students.

The amended complaint claims that Principal Matthew Sammartino "refused to turn over the videos to Youngstown Police without a subpoena, even though the video contained child pornography." The complaint argues that the players "destroyed evidence by deleting the football team’s Snapchat account," claiming this constitutes a "cover-up."

The initial complaint, like the amended version, is structured around a federal civil-rights action alleging Title IX violations for creating and tolerating a hostile educational environment based on gender. The amended complaint asserts civil liability under Ohio law for the alleged criminal acts, including hazing, distributing intimate images, tampering with evidence and records, and obstruction of justice. The legal action continues to seek economic and non-economic damages, including pain, suffering, reputational harm, and emotional distress, along with punitive damages for alleged malicious and willful conduct.

The defendants have not yet filed a reply to the corrected complaint. However, the defense team representing the Diocese, Ursuline High School, Sammartino, and Damore had previously disputed the "allegations and conclusions" presented in the plaintiffs' initial motion for an extension of time.