Young v. Salt Lake City School District

Supreme Court of Utah · 2002 · Torts

TortsNegligenceDutySpecial Relationshipschool districtstudent injurycrosswalkcustody

Facts

Young, an elementary school student, was struck by a car while riding his bicycle to a mandatory parent-teacher-student conference at Dilworth Elementary. The accident occurred at a crosswalk across from the school on a city street, not on premises controlled by the District. Young alleged the District failed to inform Salt Lake City of dangerous parking conditions near the crosswalk and failed to provide a crossing guard and flashing warning lights. The District moved for summary judgment, arguing it owed no such duties.

Issue

Did the school district owe Young a common law duty, a regulatory duty under Utah Administrative Code rule 920-5-2(A)(3), or a statutory duty under Utah Code subsection 41-6-20.1(3) for injuries he suffered at a city crosswalk while traveling to a mandatory school conference?

Rule

A defendant ordinarily has no affirmative common law duty to protect another from harm unless a special relationship exists. For a school district, any special relationship with a student is limited to the period of the district's custody over the child; without custody, no protective obligation arises. An administrative regulation creates no private right of action absent a clear indication of such intent, and subsection 41-6-20.1(3) applies only to a "local authority," meaning an entity with authority to enact traffic laws.

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

After classes ended for the day at Maple Terrace Elementary in Columbus, Ohio, nine-year-old Lena Ortiz left campus and began walking home. Two blocks away, on a city-owned street, she was hit by a delivery van; her family alleges the district had long known the intersection was dangerous but never asked the city to add signs or a crossing guard.

In Lena's negligence action against the school district, which is the strongest argument under the majority rule for summary judgment in favor of the district?

Explanation. The majority rule is that there is ordinarily no affirmative duty to protect another from harm absent a special relationship. For a school district, the special relationship is limited to the period of the district's custody over the child. Where school has adjourned, the student has been released, and the injury occurs off premises not controlled by the district, the district lacks custody and therefore owes no affirmative common-law duty to report dangers, request protections, or provide traffic measures.