J.People v. Carlsbad Unified School Dist. CA4/1
232 Cal. App. 4th 323
| Cal. Ct. App. | 2014Background
- J.P. and E.B. sues Carlsbad Unified School District (CUSD) for negligent supervision of a teacher who molested them; Firth the teacher is not a party on appeal.
- Parents were repeatedly told by CUSD administrators, with prosecutor's involvement, not to discuss the incident to protect the criminal case.
- The abuse occurred before 2009, so Government Code 911.2 government claim six-month requirement applied.
- Minors alleged equitable estoppel to toll the six-month government claim deadline due to CUSD's silence and warnings.
- Jury found CUSD negligent and estopped from enforcing the six-month limit; J. and E. awarded future economic and non-economic damages.
- Trial court denied nonsuit, denied JNOV, and denied new trial; appeal followed by CUSD challenging estoppel, jury instructions, verdict form, and damages
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether equitable estoppel tolls the government claim deadline | J.P. and E.B. | CUSD | Equitable estoppel applied; delay tolled deadline |
| Whether failure to include all estoppel elements in instructions was error | CACI 456 omission not fatal | Statement of elements required | No reversible error; proper instructions and verdict form sufficed |
| Whether the special verdict form was fatally defective | Form adequately conveyed estoppel | Needed separate elements | Not fatally defective; questions adequate |
| Whether future medical damages were supported by substantial evidence | expert and lay evidence supported $200,000 per minor | $200,000 not supported | Evidence supports award of $200,000 per minor |
Key Cases Cited
- John R. v. Oakland Unified School Dist., 48 Cal.3d 438 (Cal. 1989) (estoppel when public entity deters filing)
- Christopher P. v. Mojave Unified School Dist., 19 Cal.App.4th 165 (Cal. App. 1993) (estoppel where conduct induces delay)
- Ortega v. Pajaro Valley Unified School Dist., 64 Cal.App.4th 1023 (Cal. App. 1998) (estoppel and reliance standards)
- Vu v. Prudential Property & Casualty Co., 26 Cal.4th 1142 (Cal. 2001) (equitable estoppel; delay caused by defendant's conduct)
- Shirk v. Vista Unified School Dist., 42 Cal.4th 201 (Cal. 2007) (claims timing and governmental defenses)
- Mills v. Forestex Co., 108 Cal.App.4th 625 (Cal. App. 2003) (reasonable reliance and timing issues)
- Garcia v. Duro Dyne Corp., 156 Cal.App.4th 92 (Cal. App. 2007) (future damages proof standards)
- Red Mountain, LLC v. Fallbrook Public Utility Dist., 143 Cal.App.4th 333 (Cal. App. 2006) (discretion in verdict-form design)