Conner v. Wright State Univ., 2013 Ohio 5701

Nathan Conner, a Wright State University student, died by helium asphyxiation after March 2008 events involving WSU police.
Prior January 2008 incident: Nathan admitted taking prescription meds; he was treated and later returned to school under counseling requirements.
Appellants alleged WSU failed to protect Nathan, seeking damages for negligence, wrongful death, survivorship, and other claims.
Court of Claims granted summary judgment to WSU, finding no statutory immunity exception via a special relationship.
Appellants argued a special relationship existed, overcoming public-duty immunity; the trial court and appellate court analyzed the four-part test for such a relationship and ultimately affirmed immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a special relationship existed between WSU and Nathan.	Conner asserted WSU assumed a duty via treatment/counseling.	WSU argued no special relationship existed.	No complete special relationship; immunity applies.
Whether Nathan relied justifiably on WSU undertaking.	Justifiable reliance by Nathan shown by treatment/counseling.	Reliance not shown; no affirmative undertaking to Nathan.	Justifiable reliance not proven; no special-relationship exception.

Warrensville Hts. v. Jennings, 58 Ohio St.3d 206 (1991) (police duty to enforce law; no special relationship absent undertaking)
Luketic v. Univ. Circle, Inc., 134 Ohio App.3d 217 (1999) (off-duty officer duty; general public protection; no special relationship)
Burgess v. Doe, 116 Ohio App.3d 61 (1996) (no special relationship from public requests for police assistance)
Drexler v. Greater Cleveland Regional Transit Auth., 80 Ohio App.3d 367 (1992) (security force not creating special duty toward individual)
Skilton v. Perry Loc. School Dist. Bd. of Edn., 2004-Ohio-2239 (Ohio) (requires four-part special-relationship test; justifiable reliance is essential)