The Regents of the University of California v. Superior Court
230 Cal. Rptr. 3d 415
| Cal. | 2018Background
- Damon Thompson, a UCLA student, exhibited auditory hallucinations, paranoid delusions, and disruptive behavior across dorm and classroom; university staff and CAPS (Counseling and Psychological Services) were repeatedly notified and monitored him.
- CAPS clinicians diagnosed possible schizophrenia, urged hospitalization and medication; Thompson intermittently participated in treatment and at times refused medication and discontinued care.
- Faculty and the university Response Team were alerted to incidents in lab classes where Thompson accused classmates (including Katherine Rosen) of insulting him; emails and meetings occurred shortly before the attack.
- On October 8, during a chemistry lab, Thompson unexpectedly stabbed classmate Katherine Rosen, causing life-threatening injuries; Thompson later was found to suffer paranoid schizophrenia and was committed to a state hospital.
- Rosen sued UCLA and employees for negligence, alleging a special-relationship duty to warn/protect students from foreseeable violence; trial court denied summary judgment, Court of Appeal reversed, and the California Supreme Court granted review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a college has a special-relationship duty to protect enrolled students from foreseeable third-party violence during curricular activities | Rosen: UCLA, as the students’ institution, had a special relationship giving rise to a duty to warn/protect foreseeable victims in classroom/lab settings | UCLA: colleges owe no such special-relationship duty to adult students; at most premises-invitee duties or no duty at all | Yes. Court holds colleges have a limited special-relationship duty to use reasonable care to protect students from foreseeable violence in the classroom and curricular activities |
| Whether duty should be categorically barred by public policy or statutory constraints | Rosen: public policy and campus safety imperatives support recognizing duty | UCLA: imposing duty would burden colleges, chill mental-health treatment, and conflict with statutory limits on public-entity premises liability | Policy factors do not justify categorical bar; Rowland factors support recognizing limited duty owed to enrolled students in curricular settings |
| Scope of duty (who, when, and extent) | Rosen: duty extends to students who are foreseeable victims while participating in school activities | UCLA: duty, if any, should be narrow or nonexistent; colleges lack control over adult students | Duty limited to enrolled students and to foreseeable risks arising in classroom or curricular activities where the college has control; reasonableness of response is case-specific |
| Whether summary judgment was proper on duty ground | Rosen: triable issues exist as to foreseeability and breach | UCLA: no duty, so summary judgment warranted | Reversed Court of Appeal; duty exists as matter of law in these circumstances; remanded to decide breach and immunity issues |
Key Cases Cited
- Tarasoff v. Regents of University of California, 17 Cal.3d 425 (discussing duty to protect/warn in special-relationship contexts)
- Avila v. Citrus Community College Dist., 38 Cal.4th 148 (recognizing duty in school-supervised athletic events)
- Peterson v. San Francisco Community College Dist., 36 Cal.3d 799 (landowner/invitee duty to warn students of known criminal dangers on campus)
- Rowland v. Christian, 69 Cal.2d 108 (factors for imposing duty of care)
- Cabral v. Ralphs Grocery Co., 51 Cal.4th 764 (duty analysis and foreseeability considerations)
- Kesner v. Superior Court, 1 Cal.5th 1132 (duty/category analysis applying Rowland factors)
- Mullins v. Pine Manor College, 389 Mass. 47 (recognizing college duty to protect resident students from foreseeable criminal attack)