Bonnie I. Meyers v. William Klein
Unreported, filed February 10, 2020 (2020)
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Rule of Law:
In a negligence action against a school district, the foreseeability element of duty is a question of law determined by whether the actual harm fell within a general field of danger which should have been anticipated, rather than the specific injury-causing event; this 'general field of danger' standard also guides the analysis of legal causation.
Facts:
- Gabriel Anderson was a student at Ferndale School District’s Windward High School during the 2014-2015 school year.
- On June 10, 2015, teacher Evan Ritchie decided to take Anderson’s physical education class off campus for a walk along West Smith Road.
- Ferndale had policies requiring parental permission for off-campus field trips or excursions, which Ritchie did not follow, although he asserted he received verbal approval from Principal Tim Kiegley.
- Ritchie took students off campus without securing additional adult supervision, leading them along a sidewalk past the school safety zone to a section of road with a 40 mph speed limit, and allowing students to be up to 200 meters away.
- To return to school, students were explicitly granted permission to cross West Smith Road at locations other than designated crosswalks, and did so, walking along the south side of the road with their backs to oncoming traffic.
- While walking on the sidewalk outside the school safety speed zone, Anderson and several other students were struck by William Klein’s SUV after Klein fell asleep at the wheel and drove off the road.
- Anderson and one other student were killed, and two other students were grievously injured.
Procedural Posture:
- Bonnie Meyers, as personal representative of Gabriel Anderson’s estate, filed a negligence lawsuit against the Ferndale School District and William Klein.
- Ferndale School District moved for summary judgment dismissal of Meyers' claims against it in the trial court.
- The trial court granted Ferndale’s motion for summary judgment, concluding, as a matter of law, that the collision was not reasonably foreseeable and thus Ferndale had no duty to take steps to prevent its occurrence.
- Meyers appealed the trial court's summary judgment order to the Washington Court of Appeals, Division One (appellant).
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Issue:
Did the trial court err in granting summary judgment to the Ferndale School District by incorrectly determining that the harm to a student was unforeseeable, thus precluding a duty, when it focused on the specific injury-causing event rather than the general field of danger created by taking students off campus for a walk along a public roadway?
Opinions:
Majority - Dwyer, J.
Yes, the trial court erred because it improperly based its determination of foreseeability on the specific harm that occurred, rather than on the general field of danger created when the school district staff took Anderson off campus for a walk along a public roadway. The court explained that foreseeability, when it concerns the existence of a duty, is a question of law, but it is not measured against the specific sequence of events or exact harm suffered. Instead, the question is whether the actual harm fell within a 'general field of danger' that should have been anticipated, as established in precedents like McLeod v. Grant County Sch. Dist. No. 128 and Hendrickson v. Moses Lake Sch. Dist. School districts have a custodial relationship with students and a duty to protect them from 'dangers reasonably to be anticipated.' The trial court's focus on the driver falling asleep and not seeing the students was an incorrect application of this standard. The record contained ample evidence—including common knowledge that cars leave their lanes, expert opinion on pedestrian accidents, and Ferndale officials acknowledging the foreseeability of harm from off-campus removal—creating a genuine issue of material fact for the jury regarding whether injury from a motor vehicle collision was foreseeable within a general field of danger. The court further rejected Ferndale's alternative argument to affirm on proximate cause, stating that legal causation is closely intertwined with the duty analysis, guided by the same 'general field of danger' foreseeability standard, as highlighted in Lowman v. Wilbur. Prior school district liability cases like N.L. v. Bethel Sch. Dist. and McLeod also support linking legal causation to the general field of danger analysis.
Analysis:
This case significantly clarifies the application of foreseeability in negligence claims against school districts, reinforcing that the duty of care extends to general fields of danger rather than specific accident details. It makes it more difficult for school districts to escape liability on summary judgment by arguing that the precise mechanism of harm was unforeseeable. By intertwining the 'general field of danger' standard for both duty and legal causation, the decision emphasizes the policy consideration of holding entities with custodial relationships accountable for risks associated with their actions, particularly when safety policies are disregarded. This ruling likely encourages school districts to adhere strictly to safety protocols for off-campus activities and to broadly consider potential hazards when supervising students outside of school grounds.
