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SABRINA LOSADA VS. PRINCETON UNIVERSITYÂ (L-0057-14, MERCER COUNTY AND STATEWIDE)
A-3606-15T4
| N.J. Super. Ct. App. Div. | Aug 24, 2017
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Background

  • Sabrina and Henry Losada sue Princeton University and Princeton Tigers Aquatic Club (PTAC) for injuries Sabrina suffered exiting a PTAC swim meet held at Princeton's DeNunzio pool.
  • PTAC, a private youth swim team unaffiliated with Princeton, rented the pool from Princeton for meets and practices.
  • The injury occurred January 14, 2012, when Sabrina stepped into a depression near a walkway at the pool building.
  • Princeton is a nonprofit educational institution; PTAC’s activities occur on Princeton’s premises but are not controlled by Princeton.
  • The Law Division granted summary judgment in favor of Princeton, finding CIA immunity because Sabrina was a beneficiary of Princeton’s educational objectives.
  • The appeal argues Princeton was not engaged in its educational objectives on the injury day and thus lacked CIA immunity; the issue centers on beneficiary status under the CIA.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
CIA immunity applicability Losadas contend Princeton was not pursuing its educational objectives when Sabrina was injured. Princeton was engaged in its charitable/educational mission; Sabrina was a beneficiary of that work. Princeton entitled to CIA immunity; Sabrina was a beneficiary.

Key Cases Cited

  • Lax v. Princeton Univ., 343 N.J. Super. 568 (App. Div. 2001) (immunity extends to rentals for social/recreational activities if use serves community needs)
  • Pomeroy v. Little League Baseball, 142 N.J. Super. 471 (App. Div. 1976) (spectators are beneficiaries of charitable works)
  • Gray v. St. Cecilia's School, 217 N.J. Super. 492 (App. Div. 1987) (beneficiary concept includes those who are unconcerned or unrelated to benefactions)
  • Ryan v. Holy Trinity Evangelical Lutheran Church, 175 N.J. 333 (2003) (two-prong test for whether an institution is a beneficiary)
  • Estate of Komninos v. Bancroft Neurohealth, Inc., 417 N.J. Super. 309 (App. Div. 2010) (education is broadly defined in CIA context)
  • Orzech v. Fairleigh Dickinson Univ., 411 N.J. Super. 198 (App. Div. 2009) (education scope not limited to purely scholastic activities)
  • Roberts v. Timber Birch-Broadmoore Athletic Ass'n, 371 N.J. Super. 189 (App. Div. 2004) (promotion of citizenship and sports can satisfy educational purpose)
  • Bloom v. Seton Hall Univ., 307 N.J. Super. 487 (App. Div. 1998) (nonprofit exclusive for educational/religious purposes affords latitude in pursuing objectives)
  • Morales v. N.J. Acad. of Aquatic Scis., 302 N.J. Super. 50 (App. Div. 1997) (educational purposes can include recreational activities)
Read the full case

Case Details

Case Name: SABRINA LOSADA VS. PRINCETON UNIVERSITYÂ (L-0057-14, MERCER COUNTY AND STATEWIDE)
Court Name: New Jersey Superior Court Appellate Division
Date Published: Aug 24, 2017
Docket Number: A-3606-15T4
Court Abbreviation: N.J. Super. Ct. App. Div.