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Keywords

contractlawsuitnegligencetestimonywillsustained
depositionnegligenceappealtrialsummary judgmentwillsustainedappellant

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Hanson v. Kynast, 24 Ohio St.3d 171, 494 N.E.2d 1091, 33 Ed. Law Rep. 455, 24 O.B.R. 403

Facts

Brian K. Hanson, a player on the visiting lacrosse team, sustained serious back injuries during a game against Ashland University. The incident occurred when he attempted to intervene in a confrontation between players, resulting in him falling and hitting his head on the ground. Following the injury, there was a delay in medical treatment due to an illegally parked car blocking the entrance to the field. Hanson filed a lawsuit against Ashland University, claiming that the university was liable for the actions of its player, William Kynast, under the doctrine of respondeat superior, and for failing to provide adequate medical personnel at the game.

Issue

Whether Ashland University is liable for the injuries sustained by Brian K. Hanson under the doctrine of respondeat superior and for negligence in failing to provide medical personnel at the lacrosse game.

Whether Ashland University is liable for the injuries sustained by Brian K. Hanson under the doctrine of respondeat superior and for negligence in failing to provide medical personnel at the lacrosse game.

Rule

A principal-agent relationship exists only when one party exercises control over the actions of another, and those actions are directed toward the attainment of an objective sought by the former. In determining agency, factors such as compensation, control, and the nature of the relationship must be considered. A university-student relationship is generally contractual, where the student pays for education and is not considered an agent of the university.

The relationship of principal and agent or master and servant exists only when one party exercises the right of control over the actions of another, and those actions are directed toward the attainment of an objective which the former seeks. (Councell v. Douglas [1955], 163 Ohio St. 292, 126 N.E.2d 597 [56 O.O. 262]; Baird v. Sickler [1982], 69 Ohio St.2d 652, 433 N.E.2d 593 [23 O.O.3d 532], approved and followed.)

Analysis

In this case, Kynast was not under the control of Ashland University as he was a voluntary participant who purchased his own equipment and received no compensation. The court found that Kynast's actions during the game were not directed toward the university's objectives, and thus, no agency relationship existed. Additionally, the delay in medical treatment did not result in further injury to Hanson, as medical testimony indicated that his injuries were sustained at the moment of impact.

In order to make this determination we must examine the relevant documentary evidence produced before the trial court. A review of the evidence reveals that William Kynast expressed an interest in Ashland when he was in high school. He requested and received written information from the university and he spoke with Ashland lacrosse coach Dick Fahrney. In his deposition Kynast testified that he chose Ashland because it had a good business school, he could live away from home, and he would be able to play lacrosse. He also testified that no promises were made to him by any Ashland official to induce him to attend the university.

Conclusion

The court concluded that Ashland University was not liable for Hanson's injuries, as there was no principal-agent relationship between Kynast and the university, and the university's failure to provide medical personnel did not proximately cause additional harm.

The judgment of the court of appeals is reversed.

Who won?

Ashland University prevailed in this case because the court found that there was no agency relationship between the university and Kynast, the player who caused the injury. The court emphasized that Kynast acted independently and was not under the university's control during the game. Furthermore, the evidence showed that the delay in medical treatment did not contribute to Hanson's injuries, as they were sustained at the moment of impact.

The court concluded that Ashland University was not liable for Hanson's injuries through the doctrine of respondeat superior, and that the trial court otherwise acted appropriately in granting summary judgment for appellant.

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