Estate of Steven Jacob Jahn v. William T Farnsworth
329613
| Mich. Ct. App. | May 23, 2017Background
- On March 19, 2012, 17-year-old Marysville High School student Steven (Jake) Jahn was accused of stealing a teacher’s laptop; school officials (principal Farnsworth, assistant principal Valko, and acting superintendent Speilburg) handled the matter as a discipline issue rather than a criminal referral.
- Jake was questioned at school, initially denied, then admitted taking and reimaging the laptop; his father retrieved the laptop from Jake’s home and was informed of the suspension and possible long-term suspension.
- Alleging intimidation, misrepresentations about surveillance video, and threats to involve police or notify colleges, plaintiff contends school officials’ conduct caused severe emotional distress and suicide later that day (Jake died after driving his car into a concrete pillar).
- Plaintiff sued (negligence and intentional/reckless infliction of emotional distress); defendants moved for summary disposition arguing governmental immunity, lack of duty/proximate cause, and that federal action disposed of related due-process claims.
- The trial court granted summary disposition, holding (1) Marysville Schools and the individual defendants were entitled to governmental immunity, (2) defendants’ conduct was not extreme/outrageous or grossly negligent, and (3) Jake’s suicide was the immediate proximate cause of death.
- This Court affirmed, rejecting plaintiff’s arguments that factual disputes precluded immunity and that experts showed gross negligence or that conduct met the extreme/outrageous standard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether governmental immunity bars intentional/reckless infliction of emotional distress claim | Jahn: Officials’ interrogation, lies about video, threats, and intimidation were extreme/outrageous and not in good faith | Defs: Actions were discretionary, within authority, taken in good faith; not extreme/outrageous | Held: Immunity applies; conduct was not extreme and outrageous; claim barred |
| Whether governmental immunity bars negligence claim (gross negligence exception) | Jahn: Officials were grossly negligent by failing to follow suicide-prevention policies and by coercive conduct; causation exists | Defs: Actions were discretionary and not grossly negligent; no duty at time of death; Jake’s suicide was the immediate proximate cause | Held: Immunity applies; no gross negligence shown; defendants’ conduct was not the proximate cause |
| Whether res judicata/collateral estoppel preclude state claims based on prior federal suit | Jahn: Federal dismissal without prejudice of state-law claims does not preclude this action | Defs: Prior federal adjudication of due-process claims bears on present claims | Held: Trial court correctly rejected res judicata/collateral estoppel bar; federal dismissal did not adjudicate these state tort claims |
Key Cases Cited
- Odom v. Wayne County, 482 Mich 459 (discretionary-function and good-faith analysis for governmental immunity)
- Robinson v. Detroit, 462 Mich 439 (definition of proximate cause as the most immediate, efficient, and direct cause)
- Lewis v. LeGrow, 258 Mich App 175 (elements for intentional or reckless infliction of emotional distress)
- Pierce v. Lansing, 265 Mich App 174 (governmental-immunity questions as issues of law when facts undisputed)
- Herman v. Detroit, 261 Mich App 141 (standard of review for governmental immunity)
- Tarlea v. Crabtree, 263 Mich App 80 (gross-negligence standard under MCL 691.1407)
- Cooper v. Washtenaw County, 270 Mich App 506 (proximate-cause analysis distinguishing intervening intentional acts)
- Jahn v. Farnsworth, 33 F. Supp. 3d 866 (E.D. Mich. 2014) (prior federal decision on due-process claims)