Young Ex Rel. Young v. Salt Lake City School District
52 P.3d 1230, 452 Utah Adv. Rep. 32, 2002 UT 64 (2002)
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Rule of Law:
A school district does not owe common law, regulatory, or statutory duties to a student injured off school premises and outside regular school hours while traveling to a mandatory school event, unless the district has custody over the student at the time of the injury, or the relevant statutes or regulations expressly create such a duty or private cause of action.
Facts:
- On October 15, 1996, Eric Young, a minor, was riding his bicycle to a mandatory parent-teacher-student (PTS) conference at Dilworth Elementary, a school operated by the District.
- Young was accidentally struck and injured by a car driven by Linda Frost.
- The accident occurred just opposite Dilworth Elementary at a crosswalk located at approximately 1958 South 2100 East, Salt Lake City, Utah.
- Jennifer Wimmer had parked her vehicle illegally near the crosswalk, obstructing both Young's view of oncoming traffic and Frost's view of pedestrians.
- Young had reached a prior settlement with Linda Frost, so he did not sue her in this action.
Procedural Posture:
- On October 28, 1997, Young, acting through his mother, sued Jennifer Wimmer, claiming she had parked illegally near the crosswalk.
- Young later amended his complaint on February 23, 1998, adding the Salt Lake City School District and Salt Lake City as defendants, alleging the District failed to provide a crossing guard and flashing warning lights, and Salt Lake City failed to erect appropriate road signals.
- Young amended his complaint a second, third, and fourth time, eventually naming only the District and its agents as defendants, asserting the District had neglected to inform Salt Lake City of dangerous parking conditions and breached its duty to provide a crossing guard and flashing warning lights.
- The District filed a motion for summary judgment, arguing it had no duty to inform Salt Lake City of dangerous conditions, supply a crossing guard, or provide flashing warning lights.
- The district court granted the District's summary judgment motion, concluding that no duty existed between the defendant and plaintiff with respect to traffic signs and conditions at or around the crosswalk.
- Young appealed the district court's summary judgment ruling to the Utah Supreme Court.
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Issue:
Does a school district owe a common law, regulatory, or statutory duty to an elementary school student injured in a public crosswalk off school premises, while traveling to a mandatory school conference, for failing to report dangerous conditions or provide crossing guards/warning lights?
Opinions:
Majority - Durrant, Associate Chief Justice
No, the Salt Lake City School District did not owe Eric Young common law, regulatory, or statutory duties under the circumstances. The court concluded that the District owed Young no common law duties because it lacked a special relationship with him at the time of the accident. A special relationship between a school district and a child, which would create a common law duty to protect, is limited to the district's custody over that child. The District did not have custody of Young when he was injured because elementary school had adjourned, he had been released into the care of his parents, the injury occurred on city-controlled premises (a crosswalk where the District had no authority to regulate traffic), and Young was merely traveling to, not participating in, a school-sponsored event. The court also found no regulatory duties, as rule 920-5-2(A)(8) of Utah's Administrative Code, which requires safe routing plans, does not expressly or implicitly create a private cause of action against the District for failing to report dangerous conditions. Lastly, the court determined there were no statutory duties because subsection 41-6-20.1(3) of the Utah Code, which mandates crossing guards and warning lights in school zones, applies only to 'local authorities' with the power to enact traffic laws, a power the District does not possess. Therefore, the plain language of the statute did not impose these duties on the District.
Dissenting - Durham, Chief Justice
Yes, Chief Justice Durham dissented, arguing that a special relationship existed between the injured student and the District, creating at least a minimal common law duty to inform the city of the need for a safe crosswalk and crossing guard. She contended that the majority's rigid focus on 'custody' was contrary to Utah's prior policy-based approach for determining special relationships. This policy approach considers factors such as: (1) the foreseeability of the harm (high risk to young children, low burden for the school to report known dangers adjacent to school property); (2) the relationship between the parties (parents reasonably relied on the school, which scheduled the mandatory conference and knew of the danger); and (3) the ease with which the duty could have been fulfilled (a simple phone call to the city). Chief Justice Durham highlighted that the danger was immediately adjacent to the school, parents had reported concerns, and the mandatory conference was scheduled when no crossing guard was present, making harm highly foreseeable. She distinguished cases relied upon by the majority, noting Young was "right in front of the school" and returning for a mandatory meeting, unlike students in those cases who were further away or not involved in a direct school event at the time of injury. She also argued that imposing such a duty, limited to reporting known dangers close to school on important pathways, would not be an undue burden and would serve the overarching policy of preventing future harm.
Analysis:
This case significantly narrows the scope of a school district's common law duties, particularly regarding student safety off school grounds and outside regular school hours. By focusing on a strict interpretation of 'custody' for establishing a special relationship, the Utah Supreme Court reinforces the principle that duties to protect generally do not extend beyond the physical and temporal boundaries of direct control. The ruling also clarifies that statutory and regulatory obligations on school districts are limited by their plain language and the absence of an explicit private right of action, placing the primary responsibility for public street safety on the relevant municipal authorities. Future cases will likely use this precedent to limit liability for schools where injuries occur off-campus or when students are not under direct supervision.
