Young ex rel. Young v. Salt Lake City School District

Summary

The Utah Supreme Court affirmed summary judgment for the Salt Lake City School District in a negligence action arising from a student's bicycle accident while traveling to a mandatory parent-teacher-student conference. The majority held that the District owed no common-law duty because it lacked custody of the student and therefore had no special relationship with him at the time of the accident. It also held that the cited administrative regulation created no private right of action and that the statutory duties concerning crossing guards and warning lights applied only to entities authorized to enact traffic laws; Chief Justice Durham dissented.

Holdings

1. The District owed Young no affirmative common-law duty to report dangerous conditions, request a crossing guard, or provide flashing warning lights because it lacked custody of Young and therefore had no special relationship with him at the time of the accident.
2. Utah Administrative Code rule R920-5-2(A)(3) does not create a private cause of action against a school district for failing to report known dangerous parking conditions.
3. Utah Code section 41-6-20.1(3) imposed no duty on the District to provide a crossing guard or flashing warning lights because the District was not a statutory 'local authority.'

Questions Presented

1. Whether the Salt Lake City School District owed Young a common-law duty based on a special relationship while he was traveling to a mandatory school conference after school hours.
2. Whether Utah Administrative Code rule R920-5-2(A)(3) created a private cause of action or regulatory duty requiring the District to report dangerous parking conditions near the crosswalk.
3. Whether Utah Code section 41-6-20.1(3) imposed statutory duties on the District to provide a crossing guard and flashing warning lights.

Disposition

affirmed