Coghlan v. Beta Theta Pi Fraternity
1999 Ida. LEXIS 108, 133 Idaho 388, 987 P.2d 300 (1999)
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Rule of Law:
While universities and sororities do not have an inherent special relationship creating a duty to protect adult students from their own voluntary intoxication, they may be held liable under the assumed duty doctrine if they voluntarily undertake to protect a student and perform that undertaking negligently. Additionally, Idaho's Dram Shop Act, which bars an intoxicated person from suing the provider of alcohol, is a constitutional exercise of legislative power.
Facts:
- Rejena Coghlan, an 18-year-old freshman at the University of Idaho, pledged the Alpha Phi Sorority.
- At the end of 'Rush Week' on August 19, 1993, Alpha Phi assigned Coghlan a 'guardian angel,' an older sorority member, for a night of fraternity parties, but the assigned member told Coghlan she would not be accompanying her.
- Coghlan attended two fraternity parties, the 'Jack Daniels' Birthday' party and the 'Fifty Ways to Lose Your Liver' party.
- Although underage and without identification, Coghlan was served beer, whiskey, and mixed hard alcohol at the parties and became intoxicated.
- Two University of Idaho employees, who served as Greek advisors, were present at one of the parties, and one of them spoke to Coghlan.
- After becoming distraught from intoxication, a sorority sister escorted Coghlan back to the Alpha Phi house and put her to bed in a third-floor sleeping area.
- Coghlan later fell thirty feet from the third-floor fire escape platform, sustaining permanent injuries.
Procedural Posture:
- Rejena Coghlan and her family filed a negligence lawsuit in district court against the University of Idaho, the Idaho State Board of Education, Alpha Phi Sorority, and three fraternities (SAE, PKA, BTP).
- The district court granted the University defendants' motion to dismiss pursuant to I.R.C.P. 12(b)(6), holding that the University owed no duty of care to Coghlan.
- The district court granted summary judgment in favor of the BTP, PKA, and SAE Fraternities, holding that Idaho’s Dram Shop Act bars suits by an intoxicated person against the server of alcohol.
- The district court granted summary judgment in favor of Alpha Phi Sorority on Coghlan's initial and amended complaints.
- Coghlan and her family, as appellants, appealed all of the dismissals and summary judgments to the Supreme Court of Idaho.
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Issue:
Under Idaho law, can a university or sorority be held liable for injuries to a student resulting from her own voluntary intoxication based on a theory that they voluntarily assumed a duty of care?
Opinions:
Majority - Justice Silak
Yes. A university or sorority may be held liable for a student's injuries resulting from her own intoxication if their affirmative actions constitute a voluntary assumption of a duty to protect her, which is then performed negligently. The court first affirmed that Idaho's Dram Shop Act (I.C. § 23-808) is constitutional and unambiguously bars an intoxicated person's claims against alcohol providers, thus shielding the fraternities from liability. The court reasoned the statute rationally serves the legitimate government purposes of limiting dram shop liability and discouraging irresponsible drinking. Regarding the University and Alpha Phi Sorority, the court held that while the modern university-student relationship is not a 'special relationship' that imposes an inherent duty to protect (rejecting the in loco parentis doctrine), a duty can be voluntarily assumed. For the University, the presence of its employees at a party with knowledge of underage drinking was sufficient to allege an assumed duty to safeguard students. For the sorority, the acts of assigning a 'guardian angel' and later taking custody of the intoxicated Coghlan by bringing her home and putting her to bed were sufficient to create a material issue of fact as to whether it assumed a duty of reasonable care. Therefore, the dismissal and summary judgment in favor of the University and sorority were reversed.
Dissenting - Justice Walters
Justice Walters dissented from the part of the majority opinion finding the University could have assumed a duty, but did not provide a written opinion explaining his reasoning.
Analysis:
This decision illustrates the judicial shift away from the in loco parentis doctrine, confirming that universities are not general insurers of adult student safety. However, it critically establishes that institutions can still be held liable through the 'assumed duty' doctrine. The ruling signals that specific actions, such as having staff supervise events or taking an intoxicated student into care, can create legally enforceable duties where none previously existed. This precedent requires universities and student organizations to carefully consider the legal implications of their safety policies and interventions, as their actions can inadvertently create liability.
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