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Keywords

plaintiffdefendantnegligenceappealtrialmotionsummary judgmentcorporationduty of caremotion for summary judgment
plaintiffdefendantnegligencetrialmotionsummary judgmentduty of caremotion for summary judgment

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Tippecanoe School Corporation v. Reynolds, 187 N.E.3d 213, 402 Ed. Law Rep. 1125

Facts

Isabella Reynolds, a high-school cheerleader, was injured during a routine when she fell onto the hardwood floor after being dropped by her teammates. She filed a negligence claim against the Tippecanoe School Corporation (TSC), alleging negligent supervision and failure to provide a safe environment. The trial court initially denied TSC's motion for summary judgment on the negligent supervision claim but later reversed its decision. TSC appealed the ruling, arguing that the cheerleading routine was ordinary and that negligent supervision was not a separate cause of action.

Issue

Did the trial court abuse its discretion in denying TSC's motion for summary judgment on the negligent supervision claim?

Did the trial court abuse its discretion in denying TSC's motion for summary judgment on the negligent supervision claim?

Rule

To prevail on a negligence claim, a plaintiff must demonstrate that the defendant owed a duty, breached that duty, and that the breach caused a compensable injury. Under the Pfenning rule, a sports participant does not breach a duty when engaging in conduct that is ordinary in the sport, provided there is no intent or recklessness involved. Negligent supervision cannot be treated as a separate cause of action that escapes this analysis.

To prevail on a claim of negligence, a plaintiff must show: (1) the defendant owed a duty to the plaintiff; (2) the defendant breached that duty; and (3) the defendant's breach proximately caused a compensable injury.

Analysis

The court analyzed whether the cheerleading routine performed by Reynolds was ordinary within the sport of cheerleading. Evidence indicated that being hoisted into the air and caught by teammates is a common practice in cheerleading. The court concluded that the routine was indeed ordinary and that TSC did not breach its duty of care. Furthermore, the court determined that negligent supervision claims are subsumed under the ordinary conduct analysis and cannot be treated as separate claims.

Applying a general analysis of cheerleading, TSC's designated evidence demonstrates that the routine performed and the circumstances under which it was performed were ordinary. Both Reynolds and Patton testified to the nature of cheerleading which includes hoisting cheerleaders into the air and catching them as they are lowered to the ground.

Conclusion

The court reversed the trial court's decision and held that TSC was entitled to summary judgment on the negligent supervision claim, as the routine was ordinary and did not constitute a breach of duty.

We therefore reverse the judgment of the trial court and remand with instructions to enter summary judgment for TSC.

Who won?

The Tippecanoe School Corporation prevailed in this case. The court found that the cheerleading routine performed by Reynolds was ordinary within the context of the sport, and thus TSC did not breach any duty of care. The court emphasized that negligent supervision could not be treated as a separate cause of action that would allow for a different standard of review under the Pfenning rule.

TSC prevailed in this case as the court concluded that the routine performed by Reynolds was ordinary within the sport of cheerleading, and thus TSC did not breach a duty of care owed to her.

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