BL v. Caddo Parish School Board, 73 So. 3d 458

BL sued CPSB for negligent supervision of KKG, who was attacked off-campus after riding a school bus home with LNG; the incident occurred after discharge from the bus at their regular stop and away from school premises.
KKG was a 14-year-old with learning disabilities and prior behavioral issues; LNG had an extensive disciplinary record.
CPSB moved for summary judgment arguing no duty to supervise off-campus acts and no heightened duty due to KKG's mental status; court granted summary judgment.
Trial court inquired into KKG's mental status to determine supervision duty; court found no genuine issue of material fact and granted CPSB's motion.
BL appeals arguing CPSB owed a duty to supervise and a heightened duty due to KKG's mental status; appellate court reviews de novo.
The appellate court affirms summary judgment, holding no duty to supervise off-campus assault and no heightened duty based on mental status.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Duty to prevent off-campus assault	BL argues CPSB breached duty by supervising students.	CPSB owed no duty for off-campus acts after dismissal.	No duty owed under these facts.
Heightened duty due to mental status	KKG's mental condition required heightened supervision.	No expert evidence of disability; no heightened duty.	No heightened duty established.

Wallmuth v. Rapides Parish School Bd., 813 So.2d 341 (La. 2002) (school boards owe reasonable supervision, not insurers of safety)
S.J. v. Lafayette Parish School Bd., 41 So.3d 1119 (La. 2010) (not all students require constant supervision; duty is reasonable under circumstances)
Cavalier v. Ward, 723 So.2d 480 (La. App. 1st Cir. 1998) (liability exists when school board has actual custody and fails reasonable supervision)
Rambo v. Webster Parish School Bd., 745 So.2d 770 (La. App. 2d Cir. 1999) (supervision must be reasonable under the circumstances)
Samaha v. Rau, 977 So.2d 880 (La. 2008) (summary judgment standards and burden of proof on movant)