Bradshaw v. Rawlings
612 F.2d 135 (1979)
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Rule of Law:
A college does not have a legal duty to protect its adult students from injuries caused by the acts of another student who becomes intoxicated at an off-campus, school-sponsored event, as the modern college-student relationship is not a custodial one and the doctrine of in loco parentis no longer applies.
Facts:
- The sophomore class of Delaware Valley College planned its annual picnic, which was to be held off-campus.
- A faculty advisor for the sophomore class participated in the picnic's planning and co-signed a class check that was used to purchase beer.
- Flyers announcing the picnic, which featured drawings of beer mugs, were mimeographed by the college and prominently displayed across campus.
- The underage sophomore class president ordered six or seven half-kegs of beer from a distributor, Marjorie Moyer, for the event.
- On April 13, 1975, the picnic was held, and the majority of the approximately seventy-five students in attendance, including Bruce Rawlings, were underage but consumed beer.
- After leaving the picnic, Rawlings drove a car with Donald Bradshaw, a fellow student, as a passenger.
- While driving, Rawlings lost control of the vehicle and crashed, causing Bradshaw to suffer a cervical fracture that resulted in quadriplegia.
- Witnesses stated that Rawlings appeared to be under the influence of alcohol when he left the picnic.
Procedural Posture:
- Donald Bradshaw sued Delaware Valley College, Marjorie Moyer (doing business as Sunny Beverages), and the Borough of Doylestown in the U.S. District Court for the Eastern District of Pennsylvania.
- The case was tried before a jury.
- The jury found for the plaintiff, Bradshaw, and returned a verdict of $1,108,067 against all three defendants.
- Delaware Valley College, Marjorie Moyer, and the Borough of Doylestown each appealed the adverse judgment to the U.S. Court of Appeals for the Third Circuit.
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Issue:
Does a college have a legal duty to protect a student from injuries sustained in an off-campus automobile accident caused by a fellow student who became intoxicated at a school-sponsored class picnic?
Opinions:
Majority - Aldisert, Circuit Judge.
No. A college does not have a legal duty to protect a student from the negligent acts of an intoxicated fellow student under these circumstances. The court reasoned that the traditional doctrine of in loco parentis, where colleges acted as substitute parents for minor students, is no longer applicable to the modern university setting. College students are now legally considered adults with expanded rights and responsibilities. The court found that no 'special relationship' existed between the college and its adult students that would impose a custodial duty on the college to control their conduct, especially at an off-campus event. The college's internal regulation prohibiting alcohol did not, by itself, create such a custodial duty. Because Pennsylvania law does not impose liability on a private social host for serving alcohol to guests, the court predicted the state would be even less willing to impose such a duty on a college.
Analysis:
This decision marks a significant departure from the traditional doctrine of in loco parentis, reflecting a major shift in the legal relationship between universities and their students. The ruling establishes that as students have gained more legal rights and are treated as adults, the corresponding duty of care owed by the university has diminished. This precedent significantly limits a college's liability for student misconduct related to alcohol, especially for events occurring off-campus. Future cases involving student injuries will likely focus on whether the university voluntarily assumed a specific custodial duty rather than relying on the general student-college relationship.
