Regents of the University of California v. Superior Court

Supreme Court of California · Torts

Tortsdutyspecial relationshipcollege-student relationshipforeseeable violencecurricular activitiesclassroom assaultwarning

Facts

After enrolling at UCLA, Damon Thompson repeatedly reported auditory hallucinations and paranoid beliefs that other students were insulting and harassing him in dorms and classrooms. UCLA administrators, CAPS personnel, and the Response Team learned of his delusions, his possible schizophrenia, his thoughts about harming others, and incidents in which he identified particular students as tormentors in chemistry lab. On October 8, 2009, while classwork was underway in a chemistry laboratory, Thompson suddenly stabbed fellow student Katherine Rosen from behind with a kitchen knife, seriously injuring her. Rosen sued UCLA for negligence, alleging the university knew of Thompson's dangerous propensities but failed to warn or protect her.

Issue

Whether a college or university has a duty to protect its enrolled students from foreseeable violent acts by another student, and if so, under what circumstances. More specifically, the question was whether UCLA owed Rosen a duty of care in connection with a stabbing during a classroom laboratory session.

Rule

Colleges and universities have a special relationship with their enrolled students and therefore owe a duty to use reasonable care to protect them from foreseeable violence during curricular activities. The duty is limited: it arises from the college-student special relationship, applies only within the scope of school-sponsored curricular settings over which the school has some measure of control, and requires reasonable protective action or warning when the school becomes aware of a foreseeable threat.

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

At a university in Seattle, Omar Vega is enrolled in a required microbiology lecture. Over several weeks, faculty and student-affairs staff receive reports that Omar insists classmates are mocking him, has named two students in the course as his tormentors, and has said he sometimes thinks about making them "stop." During class, Omar suddenly strikes one of the named students with a metal water bottle, causing a skull fracture.

If the injured student sues the university for negligence, what is the strongest argument that the university owed her a duty of care?

Explanation. The majority held that colleges have a special relationship with enrolled students and therefore owe a duty to use reasonable care to protect them from foreseeable violence during curricular activities, especially classroom settings where the school has some measure of control. The duty does not depend on custodial control equivalent to imprisonment, is not negated merely because students are adults, and is not limited to premises-defect theories.