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Keywords

appealharassmentduty of care

appealduty of care

Related Cases

Regents of University of California v. Superior Court, 4 Cal.5th 607, 413 P.3d 656, 230 Cal.Rptr.3d 415, 352 Ed. Law Rep. 1112, 18 Cal. Daily Op. Serv. 2694, 2018 Daily Journal D.A.R. 2629

Facts

Damon Thompson, a student at UCLA, exhibited symptoms of schizophrenia and had a history of complaints about harassment from other students. Despite attempts by university staff to provide mental health support, Thompson's condition deteriorated, leading to an incident where he stabbed fellow student Katherine Rosen during a chemistry lab. Rosen subsequently sued the university, claiming it failed to protect her from Thompson's foreseeable violent conduct.

After he enrolled in the University of California at Los Angeles (UCLA), Damon Thompson experienced auditory hallucinations. He believed other students in the classroom and dormitory were criticizing him. School administrators eventually learned of Thompson's delusions and attempted to provide mental health treatment. However, one morning Thompson stabbed fellow student Katherine Rosen during a chemistry lab.

Issue

Whether the University of California owed a duty of care to protect Katherine Rosen from foreseeable violence during curricular activities.

Rule

Colleges and universities have a special relationship with their students that entails a duty to protect them from foreseeable violence during curricular activities.

Considering the unique features of the collegiate environment, we hold that universities have a special relationship with their students and a duty to protect them from foreseeable violence during curricular activities.

Analysis

The court determined that the university's relationship with its students created a duty to protect them from foreseeable harm. It found that the university had sufficient knowledge of Thompson's dangerous propensities and failed to take reasonable measures to prevent the attack on Rosen. The court emphasized that the unique environment of a university, particularly during curricular activities, necessitated a higher standard of care.

Having concluded UCLA had a duty to protect Rosen under the circumstances alleged, we need not decide whether the school had a separate duty to control Thompson's behavior to prevent the harm.

Conclusion

The Supreme Court reversed the Court of Appeal's decision and held that the university had a duty to protect Rosen from foreseeable violence, remanding the case for further proceedings.

Because the Court of Appeal reached a different conclusion, we reverse its decision and remand for further proceedings.

Who won?

The Supreme Court ruled in favor of Katherine Rosen, determining that the university had a duty of care to protect her from foreseeable violence.

The dissenting justice would have held that colleges have a special relationship with their enrolled students, 'at least when the student is in a classroom under the direct supervision of an instructor,' and have a corresponding duty to protect against foreseeable threats of violence in the classroom.

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