Angela Dextraze et al. v. Timothy Bernard et al.

Summary

The Rhode Island Supreme Court affirmed a Superior Court judgment for students and their parents in a negligence action arising from a student assault at Ponaganset High School. The Court held that the school district owed a duty to adequately supervise students and that expert testimony was not required where the evidence showed a known, foreseeable danger and a lack of supervision. The Court also upheld the jury’s finding of proximate cause and denied the school district’s motions for judgment as a matter of law and a new trial.

Holdings

1. Expert testimony is not required where the school district exercises no degree of care in the face of a known and foreseeable danger to students and the failure to act is within the common knowledge of a layperson.
2. The plaintiffs presented sufficient evidence for the jury to find that the school district breached its duty to adequately supervise students.
3. The plaintiffs presented sufficient facts for a jury to find that the school district's failure to act was a substantial cause of the plaintiffs' injuries.
4. The Superior Court properly denied the school district's motions for judgment as a matter of law and for a new trial because the evidence supported the jury's negligence verdict and the trial justice applied the proper standards.

Questions Presented

1. Whether the school district was entitled to judgment as a matter of law because the plaintiffs failed to establish the applicable standard of care and deviation from that standard.
2. Whether expert testimony was required to establish the school district's breach of its duty to adequately supervise students.
3. Whether the plaintiffs presented sufficient evidence for a jury to find that the school district's failure to supervise was a proximate cause of the plaintiffs' injuries.
4. Whether the Superior Court properly denied the school district's motion for a new trial.

Disposition

affirmed