Bell v. Northwest School of Innovative Learning, 198 Wash. App. 117

CB is a 15-year-old with disabilities who, due to Bethel District's inability to meet her needs, was housed with NW School for special education services.
CB boarded a District bus after NW School day, with the bus picking up on a sidewalk in front of NW School.
On the bus CB escalated verbally with another student; NW School staff and the bus driver attempted to de-escalate; CB later attempted to re-enter NW School but doors were locked.
District policy assigns bus drivers primary responsibility for students on the bus; a positive handoff to NW School staff is required before the bus can depart.
CB left the bus after being told to remain on the bus or call 911; she then went to a library and was later sexually assaulted by a stranger, Bond.
The superior court granted summary judgment dismissing CB's negligence claims against NW School, ruling NW School owed no duty after CB left its custody; NW School appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did NW School owe a duty to CB after she left the bus?	CB argues foreseeability and entrustment create a duty beyond custody.	NW School argues no duty once CB left custody; custody rested with District.	No duty; District had custody when CB left the bus; NW School owed no duty.

N.L. v. Bethel Sch. Dist., 186 Wn.2d 422 (2016) (duty determined by custody and foreseeability in school context)
McLeod v. Grant County Sch. Dist. No. 128, 42 Wn.2d 316 (1953) (special protective relationship with entrustment of vulnerable students)
HBH v. State, 197 Wn. App. 77 (2016) (entrustment and custody concepts in protective duties)
Minahan v. W. Wash. Fair Ass’n, 117 Wn. App. 881 (2003) (duty analysis when a duty exists; off-campus harm relevance)
Pac. Nw. Shooting Park Ass’n v. City of Sequim, 158 Wn.2d 342 (2006) (summary judgment burden and custodial analysis)
Jones v. Allstate Ins. Co., 146 Wn.2d 291 (2002) (summary judgment review standard)