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