Cody v. Southfield-Lathrup School District

181 N.W.2d 81, 25 Mich. App. 33, 1970 Mich. App. LEXIS 1508
CourtMichigan Court of Appeals
DecidedJune 26, 1970
DocketDocket 8,282
StatusPublished
Cited by30 cases

This text of 181 N.W.2d 81 (Cody v. Southfield-Lathrup School District) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cody v. Southfield-Lathrup School District, 181 N.W.2d 81, 25 Mich. App. 33, 1970 Mich. App. LEXIS 1508 (Mich. Ct. App. 1970).

Opinion

Snow, J.

Plaintiff Nancy Marie Cody brought suit against the defendants for injuries she received *35 while performing a gymnastics exercise on a “mini-trampoline” in her physical education class at defendant school district’s Southfield-Lathrup High School. During her second use of the apparatus, she fell and broke both arms. Defendant Pronik, the supervising teacher, was allegedly negligent in compelling plaintiff to engage in this activity against her will; together with defendant Smythe, the principal, she is said to have failed to provide plaintiff with immediate medical attention. Plaintiff Michael Cody sought recovery for past and future medical expenses he would be obligated to pay as Nancy’s father.

Defendant school district raised the affirmative defense of immunity pursuant to MCLA § 691.1401 et seq. (Stat Ann 1969 Rev § 3.996[101] et seq.) and the circuit court granted its motion for summary judgment, including in its order the finality necessary to give rise to our jurisdiction on appeal. GrCR 1963, 518.2. Plaintiffs urge several grounds upon which the school district would not be entitled to immunity.

The school district claims essentially that it is immune from tort liability while engaged in a governmental function, relying on MCLA § 691.1407 (Stat Ann 1969 Rev § 3.996 [107]):

“Except as in this act otherwise provided, all governmental agencies shall be immune from tort liability in all cases wherein said governmental agency is engaged in the exercise and discharge of a governmental function.”

However, this section of PA 1964, No 170 was declared unconstitutional by our Court in Maki v. City of East Tawas (1969), 18 Mich App 109. 1 Therefore *36 we must revert to the common law in determining the liability of a school district.

The recent discussion of the doctrine of governmental immunity by the Michigan Supreme Court began with Williams v. City of Detroit (1961), 364 Mich 231. 2 In a five-to-three decision with three separate opinions, the Court eliminated prospectively the immunity of municipal corporations for their negligent acts. Four of the justices were willing to say, “From this date forward the judicial doctrine of governmental immunity from ordinary torts no longer exists in Michigan.” 364 Mich at 250. Subsequently the Court retreated from that position. In McDowell v. State Highway Commissioner (1961), 365 Mich 268, the Court held that Williams had not abrogated the immunity of the state for its torts. More importantly for the case before us now, the Court held in Sayers v. School District No. 1, Fractional (1962), 366 Mich 217, that Williams did not apply to school districts either, since as agencies of the state, they were cloaked with the state’s immunity. We have also held that school districts are state agencies for the purpose of tort liability. Picard v. Greisinger (1965), 2 Mich App 96; Williams v. Primary School District #3, Green Township (1966), 3 Mich App 468; Meredith v. City of Melvindale (1968), 11 Mich App 208. 3 Consequently, defendant school district’s conclusion that while in pursuit of a governmental function, it is immune from liability for its negligent acts, was not unwarranted.

*37 I. Was Southfield-Lathrup School District pursuing a governmental function in conducting a physical education class?

Plaintiffs maintain that the school district was exercising a “proprietary” function, not a governmental one, in conducting a physical education class. MCLA § 691.1413 (Stat Ann 1969 Rev § 3.996[113]) excepts the state from immunity when it is engaged in a proprietary function and defines that term as “any activity which is conducted primarily for the purpose of producing a pecuniary profit for the state, excluding, however, any activity normally supported by taxes or fees”. The word “state” by the legislature’s definition includes “the state of Michigan and its agencies”. MCLA § 691.1401(c) (Stat Ann 1969 Rev § 3.996 [101] [c]).

Recreational activities of a school have generally been considered an exercise of their governmental function. Williams v. Primary School District, supra, and Sayers, supra. Bolstering such a conclusion is the legislative mandate of MCLA § 340.781 (Stat Ann 1968 Rev § 15.3781):

“There shall be established and provided in all public schools of this State * * * physical education for pupils of both sexes, and every pupil attending such schools * * * shall take the course in physical education.”

See Lewis v. Genesee County (1963), 370 Mich 110 where a county, acting pursuant to a legislative directive, was found not liable for its negligent acts.

In addition, both our Court and the Supreme Court have liberally determined the scope of activities within the physical education program, and hence, within the governmental function of a school district. In Richards v. Birmingham School District (1957), 348 Mich 490, a football game, despite its profitable *38 nature, was held to be part of the school’s physical education program, barring plaintiff’s recovery for injuries received when bleachers collapsed. Very similar to the instant case is Picard v. Greisinger, supra, where the immunity doctrine barred plaintiff’s recovery for an eye injury received when he was struck by a basketball during a physical education class.

II. Was plaintiff’s injury the result of a dangerous or defective condition of a public building?

The state has consented to suits against itself or its political subdivisions, including school districts, for injuries resulting from dangerous or defective conditions in public buildings. 4 Plaintiffs have shown that the child’s injury occurred within a building. 5 However, the trial court correctly concluded that plaintiffs did not claim any dangerous or defective condition of the building caused or contributed to the girl’s injuries. Their action was based solely on the alleged negligence of the defendants. They assert the injuries were caused by the child’s use of the “mini-trampoline”, an object in the building, but in no way attached to it. We think the legislature’s meaning was clear in the statute, particularly by the use of the words “repair and maintain” in conjunction with “dangerous or defective condition”. We cannot construe this section to include such an injury, just by the fact it occurred in a building:

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Bluebook (online)
181 N.W.2d 81, 25 Mich. App. 33, 1970 Mich. App. LEXIS 1508, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cody-v-southfield-lathrup-school-district-michctapp-1970.