253 A.3d 411
R.I.2021Background
- In January 2012 at Ponaganset High School, student Timothy Bernard assaulted fellow student Corey Dextraze in a hallway, fracturing Corey’s jaw and dislodging teeth; Corey missed school and suffered long-term impacts.
- Bernard had an extensive disciplinary history (dating to October 2010) including a prior fight and a hallway push; the school had largely imposed only detention and suspensions and did not develop a behavioral plan or provide consistent support services before the assault.
- The high‑school handbook designated teachers as primary supervisors and required them to be visible in hallways during class changes; witnesses testified no teachers intervened while Bernard followed and yelled at Corey prior to the attack.
- Plaintiffs (Corey and his parents) sued the school district for negligence, alleging failure to adequately supervise a known, foreseeably dangerous student; the Bernards were defaulted and the school district proceeded to trial.
- A jury found the school district negligent and awarded $70,000 to Corey and $5,000 to his parents; the district’s motions for judgment as a matter of law and for a new trial were denied by the trial justice.
- On appeal the school district argued (1) plaintiffs needed expert testimony to establish the applicable standard of care/breach, and (2) plaintiffs failed to prove proximate causation; the Supreme Court affirmed the verdict.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether expert testimony was required to prove the standard of care and breach in a school‑supervision negligence claim | Dextraze: no expert required; school handbook, disciplinary records, and common‑sense supervision duties permit lay jurors to find breach. | District: Medeiros requires expert proof because school supervision practices are beyond lay knowledge. | Held: No expert required where school exercised no degree of care in face of known, foreseeable danger; breach was within lay juror competence (Daniels and Almonte distinguished Medeiros). |
| Whether plaintiffs proved proximate causation between the district’s failure to supervise and plaintiffs’ injuries | Dextraze: Bernard’s known violent history and the school’s lack of hallway supervision made the assault reasonably foreseeable and the failure to supervise a substantial cause. | District: Plaintiffs presented no evidence of causation or specific negligent acts; verdict unsupported. | Held: Sufficient evidence supported jury’s finding that lack of supervision was a proximate cause; proximate cause is ordinarily for the jury. |
| Whether the trial justice erred denying JMOL and new‑trial motions | Dextraze: trial record and handbook/legal precedent supported submission to jury; trial justice properly reviewed evidence. | District: Higher standard for JMOL/new trial not met; verdict should be set aside. | Held: Review de novo for JMOL and deferential for new trial; trial justice properly exercised discretion and did not overlook material evidence—denials affirmed. |
Key Cases Cited
- Daniels v. Fluette, 64 A.3d 302 (R.I. 2013) (schools owe duty to protect students from reasonably foreseeable harm)
- Medeiros v. Sitrin, 984 A.2d 620 (R.I. 2009) (expert testimony may be required when contested matters lie beyond common knowledge)
- Almonte v. Kurl, 46 A.3d 1 (R.I. 2012) (plaintiff must establish standard of care and breach; expert testimony required only when issue is beyond lay understanding)
- Letizio v. Ritacco, 204 A.3d 597 (R.I. 2019) (deferential standard for review of trial justice’s denial of new trial)