Hegel v. Langsam

Ohio Court of Common Pleas · 1971 · Torts

Tortsdutyuniversity liabilitystudent supervisionjudgment on the pleadingsprivate lives of studentslaw and order on campus

Facts

The plaintiffs alleged that the defendants permitted a seventeen-year-old female student enrolled at the university to become associated with criminals, be seduced, become a drug user, and be absent from her dormitory. They further alleged that the defendants failed to return her to her parents' custody on demand. The student was from Chicago, Illinois, and was attending the university. The allegations were directed at the university's supposed failure to supervise and control her personal conduct and associations.

Issue

Whether a university and its employees owe a legal duty to regulate a student's private life, control her movements and associations, and return her to her parents' custody on demand, such that failure to do so states a cause of action.

Rule

A university is an institution for the advancement of knowledge and learning, not a nursery school, boarding school, or prison. Absent some legal requirement, a university and its employees have no duty to regulate the private lives of students, control their comings and goings, or supervise their associations, and students admitted to the university are presumed sufficiently mature to conduct their own personal affairs.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nina Patel, a 19-year-old student at Lakeview University in Columbus, began spending time off campus with several local adults whom her parents believed were involved in theft and drug dealing. After Nina refused to move home, her parents sued the university, alleging its residence staff negligently failed to stop her from associating with those people.

Assuming the complaint alleges no statute or other legal requirement beyond the university's general role as an educational institution, how should the court rule on the university's motion for judgment on the pleadings?

Explanation. The majority rule is that a university is for the advancement of knowledge and learning, not a custodial institution. Absent some legal requirement, a university and its employees have no duty to regulate students' private lives or supervise their associations. Because the complaint alleges only a failure to stop off-campus social relationships, it does not state a cause of action.