Costa v. Plainville Bd. of Educ., 167 A.3d 1152

Senior class picnic held during school hours off-campus at a YMCA campground; attendance and basketball participation were voluntary.
Ricky Costa voluntarily played in a pick-up basketball game at the picnic and suffered a severe eye injury when another player poked him.
School principal LePage and some teachers/nurse supervised the picnic generally, but no school personnel were stationed at or monitoring the basketball court when the injury occurred.
Board policy required that school-sponsored activities provide for "adequate supervision," but did not specify precise supervisory actions or staffing requirements.
Plaintiffs sued town, board, and principal for negligence; defendants moved for summary judgment based on governmental immunity.
Trial court granted summary judgment finding (1) the supervision duty was discretionary, not ministerial, and (2) Costa was not an "identifiable person" for the identifiable person–imminent harm exception. Appeal affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendants' duty to supervise was ministerial (no immunity) or discretionary (immunity)	Costa: supervision policy imposed an obligation amounting to a ministerial duty; no discretion should shield defendants	Defendants: policy is general and requires judgment; supervision decisions are discretionary	Held: discretionary — policy was general and did not mandate a specific response; immunity applies
Whether identifiable person–imminent harm exception applies	Costa: as a schoolchild present during school hours, he is an identifiable person under Burns	Defendants: Costa attended voluntarily and participated in a nonmandatory activity, so he is not an identifiable person	Held: exception does not apply — voluntary attendance/participation excludes him from the narrow Burns class

DiMiceli v. Cheshire, 162 Conn. App. 216 (Conn. App. 2016) (discusses distinction between discretionary and ministerial acts under § 52-557n)
Bonington v. Westport, 297 Conn. 297 (Conn. 2010) (contrast between general duties and mandates requiring a particular response)
Violano v. Fernandez, 280 Conn. 310 (Conn. 2006) (general policy language does not negate discretion absent a clear directive)
Jahn v. Board of Education, 152 Conn. App. 652 (Conn. App. 2014) (students in voluntary, nonmandatory school activities are not within Burns identifiable class)
Burns v. Board of Education, 228 Conn. 640 (Conn. 1994) (recognizes a narrow identifiable class: schoolchildren on school property during school hours)
Lamar v. Brevetti, 173 Conn. App. 284 (Conn. App. 2017) (summary judgment standards)