Stephenson v. City of New York
978 N.E.2d 1251, 19 N.Y.3d 1031 (2012)
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Rule of Law:
A school's common-law duty to supervise students is coextensive with its physical custody and control over them and generally does not extend to incidents that occur off school property and outside of school hours. Furthermore, a school has no general common-law duty to notify parents of generalized threats made by a third party against a student.
Facts:
- On October 22, 2003, Jayvaun Stephenson, a 13-year-old student, and another student, Lorenzo McDonald, were involved in a physical altercation at their school during school hours.
- Following the fight, school officials gave both boys in-school suspensions and dismissed them at different times that day to prevent further conflict.
- On October 23, after school hours but on school grounds, Lorenzo McDonald threatened Jayvaun Stephenson.
- On the morning of October 24, 2003, before school hours began, Lorenzo McDonald assaulted Jayvaun Stephenson two blocks away from their school, causing injury.
Procedural Posture:
- Plaintiffs brought a negligence action against defendants in the Supreme Court of New York (the trial court).
- Defendants moved for summary judgment, arguing they owed no duty to the plaintiff for the off-campus incident.
- The Supreme Court denied the defendants' motion for summary judgment.
- Defendants, as appellants, appealed to the Appellate Division (the intermediate appellate court).
- The Appellate Division, with two Justices dissenting, reversed the trial court's decision and granted defendants' motion to dismiss the complaint.
- Plaintiffs, as appellants, then appealed to the Court of Appeals (the state's highest court).
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Issue:
Does a school's common-law duty to supervise its students extend to an assault that occurs off school property and before school hours, even if the school was aware of a prior altercation and threats between the students?
Opinions:
Majority - Memorandum
No. A school's duty of care does not extend to an incident occurring off school premises and before school hours, as the student is no longer within the 'orbit of its authority.' The duty to supervise stems from the school's physical custody and control over students, effectively taking the place of parents. This custodial duty ceases when the child has passed out of the school's authority and a parent is free to reassume control. Here, the school fulfilled its duty by addressing the on-campus altercation through disciplinary action. The subsequent assault occurred away from the school and before school hours, placing it outside the school's orbit of authority and control. Furthermore, the court found no common-law duty for the school to notify Jayvaun's mother of the threat, as the threatened conduct was not set to occur while the child was in the school's custody.
Analysis:
This decision reaffirms the traditional boundaries of a school's duty of supervision, emphasizing that the duty is tied directly to physical custody. It clarifies that a school's knowledge of prior student conflict does not automatically create a special duty to protect a student from harm that occurs well outside the school's temporal and geographic authority. The ruling prevents the expansion of school liability, reinforcing the principle that schools are not insurers of their students' safety at all times and in all places. This case provides a clear line for future negligence claims, limiting a school's liability to the 'orbit of its authority.'
