Rocky Mountain Planned Parenthood, Inc. v. Wagner

Summary

The Colorado Supreme Court affirmed the court of appeals’ judgment in litigation arising from the 2015 shooting at a Planned Parenthood facility in Colorado Springs. The court held that the plaintiffs presented sufficient evidence to create a genuine issue of material fact regarding whether the shooter was the predominant cause of their injuries, making summary judgment for Rocky Mountain Planned Parenthood improper. However, the court held that Planned Parenthood Federation of America did not owe the plaintiffs a legal duty and affirmed summary judgment for that entity.

Holdings

1. The evidence was sufficient to create a genuine issue of material fact as to whether the shooter's conduct was the predominant cause of plaintiffs' injuries and whether Rocky Mountain Planned Parenthood's conduct or inaction was a substantial factor in causing those injuries. Therefore, summary judgment for Rocky Mountain Planned Parenthood was improper.
2. As a matter of law, Planned Parenthood Federation of America, Inc. did not owe plaintiffs a duty of care.
3. The court of appeals erred to the extent it reviewed the duty issue as though it were reviewing a factual finding, but it reached the correct result because summary judgment is reviewed de novo.

Questions Presented

1. Whether the shooter was the predominant cause of plaintiffs' injuries as a matter of law, such that Rocky Mountain Planned Parenthood's alleged failure to implement reasonable security measures could not be a substantial factor in causing the injuries and summary judgment was proper under the Colorado Premises Liability Act.
2. Whether Planned Parenthood Federation of America, Inc. owed plaintiffs a legal duty of care based on a special relationship, control over Rocky Mountain Planned Parenthood, or an assumed duty to provide security.
3. Whether the Colorado Court of Appeals applied the proper standard in reviewing the summary judgment ruling.

Disposition

affirmed