Coe v. BOARD OF EDUC. OF TOWN OF WATERTOWN
19 A.3d 640
Conn.2011Background
- Coe sued the Watertown board of education, the town, and two teachers for injuries from a graduation dance sponsored by the board at a private facility.
- A glass goblet shattered on the floor; Coe stepped on a shard after removing footwear, injuring her left foot.
- The complaint alleged the teachers negligently supervised the dance; the trial court granted motions to strike certain provisions based on governmental immunity and lack of a common-law claim against employees.
- Section 52-557n governs municipal liability, shielding discretionary acts while allowing liability for ministerial acts; an imminent-harm exception applies to identifiable victims.
- The court analyzed whether the town and board acted with discretionary authority in sponsoring the dance off school grounds, and whether employees could be liable under statutory indemnification.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether town/board liability is barred by discretionary immunity | Coe argues exceptions to immunity apply due to identifiable victims or imminent harm. | Board/town contend the acts were discretionary and immune under § 52-557n(a)(2)(B). | Town/board immunity affirmed for discretionary acts |
| Whether imminent-harm identifiable-victim exception applies to override immunity | Coe contends an identifiable victim (Coe) faced imminent harm. | Board/town argue the exception does not apply here. | Imminent-harm exception not satisfied; immunity stands for town/board |
| Whether §52-557n allows claims against individual employees | Alleges negligence claims against Gregoire and Mangione should be permitted under §52-557n(a)(1)(A). | §52-557n(a)(1)(A) provides liability for subdivisions, not individuals. | Employees not liable under §52-557n; governmental immunity applies |
| Whether indemnification under §7-465 requires a common-law claim against employees | Claims for indemnification arise if employees are liable. | Indemnification requires a valid common-law claim against the employees. | Indemnification claim blocked due to immunity against employees |
| Whether the trial court erred by striking counts against Gregoire and Mangione | Allegations against Gregoire and Mangione state a common-law negligence claim. | Employees were immune; no viable common-law claim could proceed. | Court affirmed as to immunity; alternative ground supports dismissal |
Key Cases Cited
- Violano v. Fernandez, 280 Conn. 310 (2006) (statutory immunity analysis and pleading standard)
- Doe v. Petersen, 279 Conn. 607 (2006) (imminent harm and identifiable victims in immunity exceptions)
- Durrant v. Board of Education, 284 Conn. 91 (2007) (imminent-harm exception for identifiable class of victims; school context)
- Burns v. Board of Education, 228 Conn. 640 (1994) (duty of care framework for school-related liability)
- Bonington v. Westport, 297 Conn. 297 (2010) (distinguishing governmental and ministerial acts; qualified immunity)