Stetz v. Copley Fairlawn School Dist., 2013 Ohio 5411

E.D. attended Copley Fairlawn High School and worked in the office during study hall; she changed the school sign during her shift on Nov 8, 2010.
After lunch, E.D. returned to class with a pass; while walking with two friends toward class, she paused at a staircase and looked into her backpack.
She resumed walking and slipped down the stairs, sustaining head and neck injuries.
Kristen Stetz, E.D.’s parent, sued the school district and Board of Education for negligence under multiple theories.
The trial court granted summary judgment to the district but denied it as to the Board, finding a genuine issue about a physical defect around the stairs; the Board appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Board is immune under RC 2744.	Stetz argues Board immunity applies to prevent liability.	Board contends it is immune under the three-tier framework and exceptions do not apply.	Court reversed; immunity analysis incomplete and remanded.
Must the trial court complete all three tiers of the political-subdivision immunity analysis before ruling on summary judgment?	Complete three-tier review is required to decide immunity.	If an exception applies or defenses exist, those should be considered; filing may proceed.	Court held the trial court failed to perform the entire three-tier analysis and remanded.

Lambert v. Clancy, 125 Ohio St.3d 231 (2010-Ohio-1483) (three-tier immunity analysis framework)
Shalkhauser v. Medina, 148 Ohio App.3d 41 (2002-Ohio-222) (immunity and exceptions under RC 2744 overview)
Temple v. Wean United, Inc., 50 Ohio St.2d 317 (1977) (summary judgment standards and burden on movant)
Dresher v. Burt, 75 Ohio St.3d 280 (1996) (burden shifting on summary judgment)
Grafton v. Ohio Edison Co., 77 Ohio St.3d 102 (1996) (de novo review of summary judgment)
Kick v. Smithville W. Care Ctr., 2013-Ohio-2034 (9th Dist. Wayne) (prematurity of addressing second-tier issues when remand may moot)