Summary
The Indiana Supreme Court affirmed summary judgment for Indianapolis Public Schools and Arlington Community High School in a negligence and wrongful-death action arising from a student's murder after he left school grounds. The court held that the sixteen-year-old student was contributorily negligent as a matter of law because he left school to engage in criminal activity, barring the estate's claims under Indiana common law. The court did not address governmental immunity under the Indiana Tort Claims Act because contributory negligence was dispositive.
Topics
Practice areas
Questions Presented
- Whether the governmental defendants were entitled to summary judgment because Jaylan Murray was contributorily negligent as a matter of law.
- Whether the Indiana Tort Claims Act immunized the defendants from suit.
Holdings
- The Indiana Comparative Fault Act does not apply to governmental entities; common-law contributory negligence governs negligence claims against a public school and public school system.
- A plaintiff's contributory negligence bars recovery when the plaintiff's negligence is even slightly a cause of the alleged damages. Because Jaylan's conduct in leaving school to engage in criminal activity was unreasonable and at least a slight cause of his injuries, his estate's claims were barred as a matter of law.
- Summary judgment was proper because the undisputed facts permitted only one reasonable inference: Jaylan was contributorily negligent.
Key quotations
“Under this law, a plaintiff is barred from recovery when he or she is negligent and this negligence is even slightly the cause of the alleged damages.” (at 2)
“As such, Jaylan was contributorily negligent.” (at 4)
“Accordingly, we affirm the trial court.” (at 4)
Factual background
Sixteen-year-old Jaylan Murray left Arlington Community High School without permission through an unmonitored exit and was shot and killed several hours later. He had recently been involved in a pharmacy robbery, and the evidence indicated that he left school to engage in criminal activity, either purchasing firearms or marijuana. His estate alleged that Indianapolis Public Schools and Arlington Community High School negligently failed to monitor and supervise him.
Procedural history
The Marion Superior Court granted defendants' motion for summary judgment without detailed findings or conclusions, concluding that the estate's claims were barred. A divided Indiana Court of Appeals reversed, finding that the defendants were not immune under the Indiana Tort Claims Act and that material factual disputes existed regarding contributory negligence. The Indiana Supreme Court granted transfer and affirmed the trial court on the dispositive contributory-negligence issue, declining to address governmental immunity.