Regents of University of California v. Superior Court

Supreme Court of California
240 Cal. App. 4th 1296 (2018)

ELI5:

Rule of Law:

A university has a special relationship with its students which creates a duty to use reasonable care to protect them from foreseeable violence during curricular activities.

Facts:

Damon Thompson, a student at the University of California at Los Angeles (UCLA), began experiencing auditory hallucinations and paranoia, believing other students were criticizing and harassing him in classrooms and his dormitory.
Over several months, Thompson sent multiple complaints to professors and administrators about this perceived harassment, warning in one letter that the matter could "escalate into a more serious situation."
Multiple university employees, including professors, resident directors, and deans, became aware of Thompson's delusions, odd behavior, and belief that other students were planning to harm him.
Thompson was referred to the university's Counseling and Psychological Services (CAPS) and was evaluated at an emergency room, resulting in a diagnosis of possible schizophrenia.
During sessions with CAPS staff, Thompson admitted to having thoughts about harming the people he believed were insulting him, though he did not initially identify a specific victim.
After being expelled from university housing for pushing and threatening another resident, Thompson continued to complain about students in his chemistry lab.
Shortly before the attack, Thompson's teaching assistant noted that Thompson frequently identified fellow student Katherine Rosen as one of the students calling him stupid in the lab.
During a scheduled chemistry laboratory session, Thompson attacked Katherine Rosen from behind with a kitchen knife, stabbing her in the chest and neck.

Procedural Posture:

Katherine Rosen sued the Regents of the University of California and several UCLA employees in California superior court (trial court) for negligence.
The UCLA defendants filed a motion for summary judgment, arguing they owed no duty to protect Rosen.
The trial court denied the motion for summary judgment, finding that a duty could exist.
UCLA, as petitioner, sought a writ of mandate from the California Court of Appeal challenging the trial court's denial.
A divided Court of Appeal granted the petition, holding that UCLA owed no duty to protect Rosen and directing the trial court to grant summary judgment in its favor.
The Supreme Court of California granted review to decide the issue of duty.

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Issue:

Does a university have a special relationship with its students that imposes a duty to protect them from foreseeable violent conduct by another student during curricular activities?

Opinions:

Majority - Corrigan, J.

Yes. A university has a special relationship with its students that creates a duty to use reasonable care to protect them from foreseeable violence during curricular activities. The court departed from the historical view that universities are mere bystanders to the conduct of their adult students. It determined that the college-student relationship contains the key elements of a special relationship: dependency on the part of the students, who rely on the university for a safe learning environment, and a superior degree of control by the university over the campus environment, particularly in curricular settings like classrooms. This duty is limited to the context of school-sponsored activities and does not make universities insurers of student safety. Applying the Rowland v. Christian factors, the court concluded that public policy supports this limited duty, as campus violence is foreseeable and the burden on universities is manageable, given that many already have threat-assessment protocols in place.

Concurring - Chin, J.

Yes, but the duty should be more narrowly defined. The concurring opinion agrees that universities have a duty to protect students from foreseeable violence, but argues this duty should be strictly limited to the classroom setting, which is where the attack in this case occurred. The majority's extension of the duty to the broader and undefined categories of "curricular activities" and activities "closely related to its delivery of educational services" is unnecessary to resolve the case and will likely create confusion for lower courts. The court should have exercised greater judicial restraint and left the question of duty in non-classroom settings for a case that presents those specific facts.

Analysis:

This decision marks a significant evolution in California tort law concerning higher education, formally recognizing a "special relationship" between universities and their students that previous cases had rejected. It moves away from the post-in loco parentis "bystander" model, imposing an affirmative, albeit limited, duty of care on colleges. The ruling creates a new basis for liability and will likely influence how universities manage students exhibiting threatening behavior, requiring more robust threat assessment and intervention protocols. Future litigation will likely focus on defining the boundaries of "curricular activities" and what constitutes "reasonable care" in preventing foreseeable harm.

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