Cheryl Daniels, Individually and as Mother and Next Friend of Anthony Daniels, a minor v. Zachery Fluette et al.

Summary

The Rhode Island Supreme Court reviewed a negligence action arising from a student’s injury after another student pushed him into a bathroom window at Bishop Hendricken High School. The court held that the plaintiff failed to show a triable issue regarding negligent supervision or the school’s failure to install safety glass, and it affirmed summary judgment for the school.

Holdings

1. Assuming without deciding that the school owed Daniels a duty to supervise, a plaintiff seeking to hold a school liable for an injury caused by another student must show that the student's injurious acts could reasonably have been foreseen by the school. The absence of a teacher or administrator monitoring the bathroom, without evidence of a specific foreseeable risk or specific act or omission showing a deviation from the standard of care, did not establish breach.
2. The school was not liable for failing to install safety glass in the bathroom window because the plaintiff presented no evidence that the window received heavy use, was situated so as to pose a particular danger, or otherwise created a foreseeable risk of injury.
3. Summary judgment for Bishop Hendricken High School was proper because the plaintiff failed to produce competent evidence establishing a disputed material fact concerning breach or foreseeability.

Questions Presented

1. Whether the school breached a duty to supervise students by failing to prevent or detect the horseplay that injured Daniels.
2. Whether the school breached a duty to protect students by failing to install safety glass in the boys' bathroom window.
3. Whether summary judgment was proper where the plaintiff offered no evidence that the injury-producing conduct or the window hazard was reasonably foreseeable.

Disposition

affirmed