A.R.R. v. Tau Kappa Epsilon Fraternity, Inc., and Delta Nu Teke House Association

CourtMissouri Court of Appeals
DecidedApril 12, 2022
DocketWD84545
StatusPublished

This text of A.R.R. v. Tau Kappa Epsilon Fraternity, Inc., and Delta Nu Teke House Association (A.R.R. v. Tau Kappa Epsilon Fraternity, Inc., and Delta Nu Teke House Association) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
A.R.R. v. Tau Kappa Epsilon Fraternity, Inc., and Delta Nu Teke House Association, (Mo. Ct. App. 2022).

Opinion

In the Missouri Court of Appeals Western District

 A.R.R.,   Appellant,  v.   WD84545 TAU KAPPA EPSILON FRATERNITY,  INC.,  OPINION FILED:  Respondent;  APRIL 12, 2022  AND   DELTA NU TEKE HOUSE  ASSOCIATION,   Respondent. 

Appeal from the Circuit Court of Nodaway County, Missouri The Honorable Roger M. Prokes, Judge

Before Division Three: Anthony Rex Gabbert, Presiding Judge, Lisa White Hardwick, Judge, Thomas N. Chapman, Judge

A.R.R. appeals the circuit court’s Judgment granting Tau Kappa Epsilon Fraternity’s

(“TKE”) and TKE Delta Nu House Association’s (“House Association”) motions for summary

judgment on Counts II, III, and IV in A.R.R.’s “First Amended Petition for Damages” which

alleged, as relevant to this appeal, “Premise Liability Against All Defendants” in Count II,

“Negligent Supervision Against All Defendants” in Count III, and “Negligence Against All Defendants” in Count IV.1 A.R.R.’s claims stem from the defendants’ alleged actions and/or

inactions in relation to an alleged sexual assault of A.R.R. during a 2015 Northwest Missouri State

University Delta Nu Chapter of TKE Halloween Party. A.R.R. asserts four points on appeal which

contend that the circuit court, 1) erred in granting summary judgment in favor of TKE and House

Association (“the defendants” collectively) on Count II of the First Amended Petition, arguing that

she presented summary judgment facts supporting a claim for premises liability, 2) erred in

granting summary judgment in favor of the defendants on Count III, arguing that she presented

summary judgment facts supporting a claim for negligent supervision, 3) erred in granting

summary judgment in favor of the defendants on Count IV, arguing that she presented summary

judgment facts supporting a claim for negligence, and 4) erred in granting summary judgment in

favor of the defendants, arguing that she presented summary judgment facts supporting a claim for

negligence based an assumed duty. We affirm.

Background and Procedural Information

A.R.R. filed a First Amended Petition on October 15, 2019, alleging that she was sexually

assaulted on or about October 31 or November 1, 2015, at the fraternity house of Northwest

Missouri State University’s Delta Nu of TKE (“Delta Nu”).2 A.R.R. alleged that on October 31-

November 1, 2015, Delta Nu hosted, sponsored, and endorsed a Halloween party at the fraternity

house where alcohol was served to A.R.R. While at the fraternity house, A.R.R. became

1 A.R.R. does not appeal the circuit court’s grant of summary judgment to the defendants named in Count I (“Sexual Abuse and/or Battery Against TKE and Delta Nu”) on statute of limitations grounds. 2 Delta Nu was dismissed as a party, without prejudice, following the circuit court’s Judgment.

2 intoxicated and a Delta Nu fraternity member sexually assaulted, battered, and raped A.R.R. while

she was under the influence of alcohol and, at times, unconscious.

As relevant to this appeal, in Count II titled “Premise Liability,” A.R.R. alleged that, as

owners and operators of the premises where the assault took place, the defendants had a duty to

maintain the premises in a reasonably safe condition, knew or could have known that its premises

were not in a reasonably safe condition, failed to adhere to their duty and were negligent, and that

A.R.R. suffered harm as a result. In Count III titled “Negligent Supervision,” A.R.R. alleged that

TKE knew or should have known of the dangerous and exploitive propensities exhibited by Delta

Nu and/or that Delta Nu was an unfit fraternity chapter, and negligently failed to supervise Delta

Nu members who harmed A.R.R. Further, that House Association knew or should have known of

the dangerous and exploitive activities taking place at the fraternity house, and despite such

knowledge, failed to supervise the actions taking place which resulted in A.R.R.’s harm. In Count

IV titled “Negligence,” A.R.R. alleged that the defendants had a duty to control, discipline,

oversee, direct, and supervise the actions of Delta Nu and its fraternity members by ensuring

compliance with the law, ensuring that fraternity parties were reasonably safe by providing security

and/or preventing alcohol on the premises when appropriate, and ensuring the fraternity members

were not otherwise engaging in and/or permitting dangerous conduct to occur at such fraternity

parties or events at the fraternity house. A.R.R. alleged that the defendants knew or reasonably

should have known of the risks and dangers of sexual assaults occurring at parties hosted by Delta

Nu at the fraternity house, knew that assaults were likely to occur under the circumstances, and

failed to exercise ordinary care which resulted in harm to A.R.R.

On February 19, 2021, the defendants moved for summary judgment. On March 31, 2021,

the circuit court granted those motions. In addressing the negligence-based claims generally, the

3 court noted that the case involved a third-party criminal attack and concluded that, barring some

exception, there is generally no legal duty in negligence to protect someone from a third-party

criminal attack. The court further noted that the Missouri Supreme Court has taken the position

that a national fraternity organization is generally not liable for the conduct of a local chapter,

unless it exercises day-to-day control over the local chapter. The court concluded that TKE and

House Association had no day-to-day control of the local chapter.

With regard to the premises liability claims in Count II, the court found that the facts of the

case do not create a submissible claim of premises liability against the defendants. The court

concluded that TKE does not own or control the fraternity house, and while the House Association

owns the house, it leases the premises to individual fraternity members living in the house. The

court determined that A.R.R. was a social guest and a licensee on the premises at the time of the

incident, as there was no evidence that A.R.R. had a business purpose on the premises or that the

premises were open to the public. The court further found that, even if the defendants controlled

the premises, they had no legal duty of care with respect to serving alcohol to a social guest.

Further, in order for a duty to protect from a third-party criminal act to attach to a social host, the

social host must be present on the premises, have reason to know of his/her ability to control the

third-party, and have reason to know the necessity for exercising control. The court concluded that

the facts do not support a submissible case against the defendants on these elements.3

3 The court additionally found that, even if A.R.R. could be considered an invitee, the facts do not evidence a “special relationship” and/or “special facts and circumstances” such as would be necessary to support the defendants having a duty of care to protect A.R.R. from a third-party criminal attack.

4 With regard to the negligent supervision claims in Count III, the court found that the facts

of the case do not support a submissible claim, as there was no evidence that the defendants had a

legal duty to supervise the tenants/fraternity members under Missouri law.

With regard to A.R.R.’s Count IV negligence claim, the court noted that the First Amended

Petition does not clearly identify the basis for the defendants’ alleged duty of care in that count.

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A.R.R. v. Tau Kappa Epsilon Fraternity, Inc., and Delta Nu Teke House Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/arr-v-tau-kappa-epsilon-fraternity-inc-and-delta-nu-teke-house-moctapp-2022.