John Doe v. Varsity Spirit, LLC

CourtDistrict Court, N.D. Ohio
DecidedSeptember 20, 2024
Docket1:23-cv-01960
StatusUnknown

This text of John Doe v. Varsity Spirit, LLC (John Doe v. Varsity Spirit, LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John Doe v. Varsity Spirit, LLC, (N.D. Ohio 2024).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

JOHN DOE 1, ) CASE NO. 1:23-CV-1960 ) Plaintiff, ) JUDGE CHRISTOPHER A. BOYKO ) vs. ) ) VARSITY SPIRIT, LLC, et al. ) OPINION AND ORDER ) Defendant. )

CHRISTOPHER A. BOYKO, J.: This matter is before the Court on Defendant U.S. All-Star Federation, Inc.’s (“USASF”) Motion to Dismiss pursuant to Fed. R. Civ. P. Rule 12(b)(6). (ECF #4). Plaintiff has responded in opposition (ECF #10) and Defendant has replied in support. (ECF #12). BACKGROUND While a minor, Plaintiff John Doe was a cheerleader and paying member of USASF. Plaintiff alleges that USASF, among others, had responsibility for vetting and authorizing coaches to work with the minor athletes. (ECF #1-1). He also alleges that USASF made representations and promises to its members about athlete safety. Id. This included implementing policies and procedures designed to prevent inappropriate contact between coaches and minor athletes. Id. Despite these policies and procedures, Plaintiff alleges he was the victim of sexual abuse by two of USASF’s authorized choreographers, Defendants Brandon Hale and Taji Davis, while at an event sponsored by USASF. Id. Plaintiff asserts claims against multiple defendants alleged to be responsible for the incident, including USASF. USASF seeks dismissal of all claims against it on the basis that the claims do not have sufficient factual support to make them legally cognizable against USASF. At issue before

the Court is whether Plaintiff has alleged sufficient facts to make the following claims for relief plausible: Gross Negligence, Negligent Supervision, Unjust Enrichment, Negligent Security, Respondeat Superior, Intentional Infliction of Emotional Distress, Violation of the Consumer Sales Protection Act and Punitive Damages. LAW AND ARGUMENT “In reviewing a motion to dismiss, we construe the complaint in the light most favorable to the plaintiff, accept its allegations as true, and draw all reasonable inferences in favor of the plaintiff.” Directv, Inc. v. Treesh, 487 F.3d 471, 476 (6th Cir. 2007). Factual allegations contained in a complaint must “raise a right to relief above the speculative level.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 127 S. Ct. 1955, 167 L. Ed. 2d 929 (2007). Twombly does not “require heightened fact pleading of specifics, but only enough facts to

state a claim to relief that is plausible on its face.” Id. at 570. Dismissal is warranted if the complaint lacks an allegation as to a necessary element of the claim raised. Craighead v. E.F. Hutton & Co., 899 F.2d 485 (6th Cir. 1990). The United States Supreme Court, in Ashcroft v. Iqbal, 556 U.S. 662, 129 S. Ct. 1937, 173 L. Ed. 2d 868 (2009), discussed Twombly and provided additional analysis of the motion to dismiss standard: “In keeping with these principles a court considering a motion to dismiss can choose to begin by identifying pleadings that, because they are no more than conclusions, are not entitled to the assumption of truth. While legal conclusions can provide the framework of a complaint, they must be supported by factual allegations. When there are well-pleaded factual allegations, a court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.” Id. at 679. The Sixth Circuit holds the standard described in Twombly and Iqbal “obliges a pleader to amplify a claim with some factual allegations in those contexts where such amplification is needed to render the claim plausible.” Weisbarth v. Geauga Park Dist., 499

F.3d 538, 541 (6th Cir. 2007) (quoting Iqbal v. Hasty, 490 F.3d 143, 157-58 (2nd Cir. 2007)). The Court should disregard conclusory allegations, including legal conclusions couched as factual allegations. Twombly, 550 U.S. at 555; J&J Sports Prods. v. Kennedy, No. 1:10CV2740, 2011 U.S. Dist. LEXIS 154644, at *4 (N.D. Ohio Nov. 3, 2011). A. Counts I and V – Gross Negligence and Negligent Security At this stage of the proceeding, under Ohio law, negligence claims require the plaintiff to allege: “(1) the existence of a legal duty owed to the injured plaintiff, (2) the defendant’s breach of that duty, and (3) that an injury proximately resulted from the defendant’s breach of duty.” Snay v. Burr, 167 Ohio St.3d 123, 126 (2021) (citing Mussivand v. David, 45 Ohio St.3d 314, 318 (1989)). USASF argues Counts I and V must be dismissed for lack of a

cognizable legal duty. “Duty refers to the relationship between the plaintiff and the defendant from which arises an obligation on the part of the defendant to exercise due care toward the plaintiff.” Snay, 167 Ohio St.3d at 126. In general, an individual has no duty to prevent a third person from harming another unless there is “a special relationship between the actor and the third person which gives rise to a duty to control, or between the actor and another which gives the other the right to protection.” Godwin v. Facebook, Inc., 160 N.E.3d 372, 379 (Ohio Ct. App. 2020) (citing Fed. Steel & Wire Corp. v. Ruhlin Constr. Co., 45 Ohio St.3d 171, 173 (1989)). Ohio law recognizes several special relationships: (1) a business owner and an invitee, (2) an innkeeper and her guests, (3) a possessor of land and an invitee, (4) a custodian and an individual taken into her custody and (5) an employer and her employee. Godwin, 160 N.E.3d at 380. However, “[a] voluntary act, gratuitously undertaken, must be performed with the

exercise of due care under the circumstances.” Douglass v. Salem Cmty. Hosp., 794 N.E.2d 107, 122 (Ohio Ct. App. 2003) (quoting Briere v. Lathrop Co., 22 Ohio St.2d 166, 171-72 (1970)). “This theory of negligence does not require proof of a special relationship between the plaintiff and the defendant.” Id. Instead, this theory “follows the general rules for finding negligence, with the addition of one extra element of proof, that of reasonable reliance by the plaintiff on the actions of the defendant.” Id. Plaintiff alleges USASF made representations about the safety and protection of minor athletes and functioned as a governing body of the Varsity network. (ECF #1-1.) In that capacity, Plaintiff alleges USASF implemented policies and guidelines and a vetting process to ensure the safety of minor athletes from potentially dangerous adult coaches (Id.), i.e., it

voluntarily undertook the duty to protect Plaintiff from harm. He also alleges USASF failed to prevent Defendants Hale and Davis from accessing him when it knew they posed a threat of harm. Id. He further alleges Plaintiff entrusted USASF with his physical, mental and emotional care and well-being. Id. Accepting these allegations as true, the Court finds it is plausible that USASF voluntarily undertook a duty of care toward Plaintiff which he reasonably relied upon that USASF breached, resulting in Plaintiff’s harms. Defendant’s motion is DENIED regarding Counts I and V of the Complaint. B. Count II – Negligent Supervision Under Ohio law, negligent supervision claims require the plaintiff to allege: “(1) the existence of an employment relationship; (2) the employee’s incompetence; (3) the employer’s actual or constructive knowledge of such incompetence; (4) the employee’s act or omission causing the plaintiff’s injuries; and (5) the employer’s negligence in hiring or retaining the

employee as the proximate cause of plaintiff’s injuries.” Ruta v. Breckenridge-Remy Co., 69 Ohio St.2d 66, 69 (1982); see e.g., Sygula v. Regency Hosp.

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John Doe v. Varsity Spirit, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-doe-v-varsity-spirit-llc-ohnd-2024.