Board of Trustees of Georgia Military College v. Rose O'Donnell

CourtCourt of Appeals of Georgia
DecidedOctober 29, 2019
DocketA19A1312
StatusPublished

This text of Board of Trustees of Georgia Military College v. Rose O'Donnell (Board of Trustees of Georgia Military College v. Rose O'Donnell) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Board of Trustees of Georgia Military College v. Rose O'Donnell, (Ga. Ct. App. 2019).

Opinion

FOURTH DIVISION DOYLE, P. J., COOMER and MARKLE, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules

October 29, 2019

In the Court of Appeals of Georgia A19A1312. BOARD OF TRUSTEES OF GEORGIA MILITARY COLLEGE v. O’DONNELL.

MARKLE, Judge.

Rose O’Donnell was injured after performing a series of physical exercises as

punishment for violation of the honor code while a student at Georgia Military

College (“the College”). She filed a civil suit for negligence against the Board of

Trustees of GMC (“GMC”) and individual members of the board and staff, seeking

damages arising from the injuries she sustained. The trial court denied GMC’s motion

to dismiss, as well as its motion for summary judgment. On appeal, GMC argues that

the trial court erred in (1) denying its motion to dismiss based on the discretionary

function exception to a waiver of sovereign immunity under OCGA § 50-21-24 (2);

(2) denying its motion for summary judgment where OCGA § 20-2-1000 (b) provides for immunity for the acts or omissions of educators resulting from the discipline of

a student; and (3) denying its motion for summary judgment where no GMC educator

breached a legal duty that proximately caused O’Donnell’s injuries. Because

O’Donnell’s suit is barred by the doctrine of sovereign immunity, we reverse.

“We review de novo a trial court’s ruling on a motion to dismiss based on

sovereign immunity grounds, which is a matter of law. Factual findings are sustained

if there is evidence supporting them, and the burden of proof is on the party seeking

the waiver of immunity.” (Citation omitted.) Douglas v. Dept. of Juvenile Justice, 349

Ga. App. 10 (825 SE2d 395) (2019).

So viewed, the evidence shows that, in October 2013, O’Donnell was a high

school junior at the College when she was caught plagiarizing a biology lab report.

She admitted to violating the honor code, and was given punishment of ten hours of

“bullring,” GMC’s after school retraining session consisting of a series of physical

exercises, to be completed for one hour each day. The bullring was run by Junior

Reserve Officers’ Training Corps (“JROTC”) instructors, and the physical exercises

complied with GMC JROTC standard operating procedures (“SOPs”) and the army

physical readiness training manual (“PRT”). Per the SOPs, the instructors determined

which exercises were performed, as well as the duration and number of those

2 exercises. Students were required to complete the entire hour of bullring in order to

receive full credit; if they failed to complete the exercises, they were required to

repeat the entire hour.

On her first day of participating in bullring, O’Donnell was required to perform

numerous exercises, such as running, pushups, and lunges. She started to struggle

during her second run and set of pushups, and, although she knew that she could stop

the exercises if she needed to, she chose to proceed so that she would not have to

repeat the entire session. O’Donnell struggled through the remainder of the exercises;

she cried, was flushed, she was breathing heavily, and she felt pain in her legs, arms,

and knees. When one instructor noticed she was breathing heavily and asked if she

needed to see the nurse, O’Donnell replied that she was trying to catch her breath.

After bullring, O’Donnell noticed her arms were sore and shaking, and she took

a warm bath and placed ice on her arms once she got home that evening. At school

the next morning, O’Donnell proceeded to the nurse’s office because she could not

move her arms. The nurse noted O’Donnell had swelling in her left arm, her right arm

was sore, and she had bruising on her knees, and she gave O’Donnell an ice pack.

Unable to complete classes for that day, O’Donnell checked out of school and, when

3 her pain worsened, she sought medical treatment at a local hospital. Ultimately,

O’Donnell was diagnosed with rhabdomyolysis, a condition resulting from severe

muscle breakdown and the release of proteins into the blood stream, and was admitted

to the hospital for ten days.

As a result of her injuries, O’Donnell sued GMC and individual members of

the board and staff (collectively, “the defendants”) under the Georgia Tort Claims Act

(“GTCA”), OCGA § 50-21-20 et seq., alleging state law negligence claims and

violation of civil rights.1 GMC filed its motion for summary judgment, asserting (1)

there was no evidence any of its employees breached a duty proximately causing

O’Donnell’s injuries; and (2) GMC had immunity from O’Donnell’s claims under

OCGA § 20-2-1000 (b). GMC also filed a motion to dismiss based on the

discretionary function exception to the waiver of sovereign immunity under OCGA

§ 50-21-24 (2).

1 The named defendants removed the case from the Baldwin County Superior Court to the United States District Court for the Middle District of Georgia based on O’Donnell’s federal civil rights claim. After the district court dismissed the individually named defendants and the federal civil rights claim against them, it remanded O’Donnell’s state law claims against GMC back to superior court.

4 Following two hearings,2 the trial court denied the motions to dismiss and for

summary judgment,3 finding that OCGA §§ 20-2-732 and 20-2-1000 did not waive

immunity given to educators in connection with student disciplinary action; there was

a jury question as to whether the punishment O’Donnell endured was excessive or

unduly severe; GMC was not entitled to sovereign immunity under the exception to

the GTCA’s waiver of immunity under OCGA § 50-21-24 (2); and there was a jury

question as to whether GMC breached a duty of care to O’Donnell, and whether that

breach was the proximate cause of her injuries. GMC filed an application for

interlocutory review, which this Court granted. This appeal followed.

1. GMC argues that the trial court erred in failing to dismiss O’Donnell’s

negligence claims against it because her claims are barred by sovereign immunity.

Specifically, GMC contends that, although the GTCA provides a limited waiver of

2 The record does not contain a transcript of the first hearing. However, given that the purpose of the hearings was to have argument rather than to admit evidence, the absence of a transcript does not hinder our review. See League v. Citibank (South Dakota), 291 Ga. App. 866, 867-868 (1) (663 SE2d 266) (2008). 3 The trial court entered an order denying GMC’s motion to dismiss, finding it had subject matter jurisdiction for the reasons explained in its order on GMC’s motion for summary judgment. The trial court also entered a separate order denying GMC’s motion for summary judgment.

5 immunity to state officers and employees, the conduct complained of here falls within

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Board of Trustees of Georgia Military College v. Rose O'Donnell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/board-of-trustees-of-georgia-military-college-v-rose-odonnell-gactapp-2019.