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Keywords

tortliabilitymotionwillmotion to dismiss

negligenceliabilitystatutewill

Related Cases

R.B. by Hickey v. Enterline, 304 F.Supp.3d 456, 355 Ed. Law Rep. 708

Facts

On September 10, 2014, Benjamin fell and struck her head on the ground during cheerleading practice… Enterline did not notify Benjamin's parents of the injury nor did she have Benjamin assessed by the school's athletic trainer or other medical personnel.

Issue

Did the coach's actions constitute willful misconduct under Pennsylvania law, and was she entitled to qualified immunity for the alleged constitutional violation?

Whether the coach's actions constituted willful misconduct under Pennsylvania law and whether she was entitled to qualified immunity for the alleged constitutional violation.

Rule

Analysis

Although Enterline would be immune for negligence, as provided by the statute, that immunity does not extend to 'acts or conduct which constitutes a crime, actual fraud, actual malice or willful misconduct.'… Here, there are no allegations that Enterline was acting in a manner that evinces an intent for Benjamin to suffer a concussion. Enterline's actions sound in negligence, but simply do not rise to the level of intentional conduct necessary to lose immunity under the Act at issue.

Conclusion

The court granted the motion to dismiss, holding that Enterline was immune from liability for the state law claim and entitled to qualified immunity for the federal claim.

Consequently, I am compelled to consider what was firmly established law during the time of the events in question… For all of the foregoing reasons, Enterline is immune from liability for both the state law and federal law claims. Accordingly, this action must be dismissed.

Who won?

The court ruled in favor of the coach, Jennifer Enterline, concluding that she was immune from liability under state law and entitled to qualified immunity under federal law. The court determined that the allegations did not rise to the level of willful misconduct necessary to overcome the immunity provided by the Pennsylvania Political Subdivision Tort Claims Act, and that the constitutional violation was not clearly established at the time of the incident.

The court ruled in favor of Enterline, stating that 'Enterline is immune from liability for both the state law and federal law claims.'

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