LOUISE ROYAL v. GEORGIA SCHOOL BOARDS ASSOCIATION RISK MANAGEMENT FUND

CourtCourt of Appeals of Georgia
DecidedFebruary 17, 2022
DocketA21A1596
StatusPublished

This text of LOUISE ROYAL v. GEORGIA SCHOOL BOARDS ASSOCIATION RISK MANAGEMENT FUND (LOUISE ROYAL v. GEORGIA SCHOOL BOARDS ASSOCIATION RISK MANAGEMENT FUND) 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
LOUISE ROYAL v. GEORGIA SCHOOL BOARDS ASSOCIATION RISK MANAGEMENT FUND, (Ga. Ct. App. 2022).

Opinion

FIRST DIVISION BARNES, P. J., GOBEIL 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. https://www.gaappeals.us/rules

February 17, 2022

In the Court of Appeals of Georgia A21A1595, A21A1596. GEORGIA SCHOOL BOARDS ASSOCIATION RISK MANAGEMENT FUND v. ROYAL et al.; and vice versa.

MARKLE, Judge.

After teacher Louise Royal was violently attacked at school by Neotha Fedd,

the parent of a student, she and her husband filed a civil suit against Fedd and

obtained a default judgment against her. Royal then sued the Georgia School Boards

Association Risk Management Fund, Inc. (“the Fund”) as Fedd’s judgment creditor,

seeking to collect the default judgment under a Casualty & Crime Coverage

Agreement (“the Agreement”) between it and the Seminole County Board of

Education (BOE). The trial court denied both parties’ summary judgment motions on

the issue of whether Fedd was covered under the provisions of the Agreement. The

trial court further granted summary judgment in favor of Royal and against the Fund, finding that the Agreement’s exclusion for willful violations of a penal statute was

unenforceable as a matter of law. In a separate order, the trial court also granted

Royal’s motion in limine to exclude Fedd’s criminal conviction. Both parties now

appeal.

In Case No. A21A1595, the Fund contends that the trial court erred by denying

its summary judgment motion, arguing that Fedd was not covered by the Agreement

because she did not qualify, and was not acting, as an authorized volunteer of the

school at the time of the attack. The Fund further asserts that the trial court erred by

granting summary judgment in Royal’s favor because the Agreement excluded

coverage for the wilful violation of a criminal statute, thus barring recovery for

Fedd’s attack on Royal. Finally, the Fund argues that the trial court abused its

discretion in excluding Fedd’s criminal conviction from evidence. In Case No.

A21A1596, Royal argues that the trial court erred in denying her summary judgment

motion by instead finding that there remained a question of fact as to whether Fedd

was covered under the Agreement as an authorized volunteer at the school on the day

of the attack. Because we conclude that Fedd was not covered under the Agreement,

we reverse the trial court’s denial of the Fund’s summary judgment motion and

2 remand the cases to the trial court with instruction to enter judgment in the Fund’s

favor.

In order to prevail on a motion for summary judgment under OCGA § 9-11-56, . . . [a] moving party, must show that there exists no genuine issue of material fact, and that the undisputed facts, viewed in the light most favorable to the nonmoving party, demand judgment as a matter of law. Moreover, on appeal from the denial or grant of summary judgment the appellate court is to conduct a de novo review of the evidence to determine whether there exists a genuine issue of material fact, and whether the undisputed facts, viewed in the light most favorable to the nonmoving party, warrant judgment as a matter of law.

(Citation omitted.) In/Ex Systems v. Maud, 352 Ga. App. 722, 723 (2) (835 SE2d 799)

(2019).

So viewed, the record shows the following. One morning in May 2013, Royal,

a teacher, was working as a hall monitor at the Seminole County elementary school

before classes began when she encountered Fedd. Fedd had a first grader who

attended the school and was scheduled to participate in a field trip that day. Without

provocation, Fedd violently attacked Royal, causing her permanent injuries.1

1 Royal received workers’ compensation benefits as a result of her injuries. Thus, the BOE is not named as a defendant. See Mullinax v. Pilgrim’s Pride Corp., 354 Ga. App. 186, 188 (1) (a) (840 SE2d 666) (2020) (OCGA § 34-9-11 (a) of the Workers’ Compensation Act “provides the employee’s exclusive remedy against his

3 The BOE carries a self-insurance policy through the Fund, which is an

interlocal risk management agency, or self-insurance fund, that provides liability

coverage to member school systems. The Fund issued the Agreement to the BOE,

effective July 2012 through July 2013, which covered the BOE as “the Named

Member” as well as certain designated individuals when they are “authorized” by the

BOE or acting within the scope of their employment.

The parties dispute whether Fedd was covered by the Agreement as an

authorized volunteer at the school. Specifically, in the “Common General Conditions”

section of the Agreement, it provides:

It is agreed that the unqualified word ‘Member’ wherever used in this coverage document includes not only the Named Member but also; . . . [a]ny of the following, within the scope of their employment, or authorized by the Named Member; . . . (2) Authorized Volunteers[.]

The Agreement does not define the term “authorized.”

Following the attack, Royal made demand upon the Fund for the coverage

limit, contending that the Agreement covered the actions of Fedd. Royal asserted that

Fedd was covered not under the “Bodily Injury and Property Damage Liability”

employer and precludes recovery on a tort claim by an injured employee against his employer.”) (citation omitted).

4 sections of the Agreement, but under “the Personal and Advertising Injury Liability”

provisions, which extend coverage to “[p]ersonal injury caused by an offense arising

out of the Named Member’s business[.]”2 The Agreement defines “personal injury”

as an injury, other than bodily injury, arising out of offenses including “false arrest,

detention or imprisonment.” However, the Agreement also excludes coverage for

“[p]ersonal injury . . . arising out of the willful violation of a penal statute or

ordinance committed by or with the consent of the Member.” In response to Royal’s

demand, the Fund denied coverage.

After Fedd was tried and convicted for her attack, Royal and her husband filed

a civil suit against Fedd (“the underlying action”), asserting claims for negligence and

negligence per se; false arrest, detention or imprisonment; assault and battery;

negligent and intentional infliction of emotional distress; civil rights violations; loss

of consortium; and compensatory and punitive damages. Royal ultimately obtained

a default judgment against Fedd in the amount of $1,850,000. Royal then filed the

instant suit against the Fund as Fedd’s judgment creditor.3

2 Royal conceded below there was no coverage for her claims under the “Bodily Injury and Property Damage Liability” provision of the Agreement. 3 This action was originally filed in Pulaski County Superior Court, and subsequently transferred to Gwinnett County Superior Court per the parties’

5 Both parties filed motions for summary judgment on the issue of whether the

Agreement covered Fedd. The Fund argued that Fedd was not covered under the

Agreement because she was neither an authorized volunteer in general at the time of

the attack nor was she authorized by the BOE when she attacked Royal. It also

asserted that, even if Fedd fell within the Agreement’s coverage, the exclusion for the

willful violation of a penal statute barred coverage.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Atlanta Casualty Insurance v. Gardenhire
545 S.E.2d 182 (Court of Appeals of Georgia, 2001)
Southern Fire & Casualty Co. v. Jamerson
479 S.E.2d 404 (Court of Appeals of Georgia, 1996)
Kent v. Kent
452 S.E.2d 764 (Supreme Court of Georgia, 1995)
Georgia Farm Bureau Mutual Insurance Company v. Smith
784 S.E.2d 422 (Supreme Court of Georgia, 2016)
Alr Oglethorpe v. C. Gerald Henderson
783 S.E.2d 187 (Court of Appeals of Georgia, 2016)
Georgia Interlocal Risk Management Agency v. City of Sandy Springs
788 S.E.2d 74 (Court of Appeals of Georgia, 2016)
Johnny Wilson v. Clark Atlanta University, Inc.
794 S.E.2d 422 (Court of Appeals of Georgia, 2016)
Harold Dwayne Sharpe v. Great Midwest Insurance Company
808 S.E.2d 563 (Court of Appeals of Georgia, 2017)
Hale Haven Properties, LLC v. Bank of America, N.A.
815 S.E.2d 574 (Court of Appeals of Georgia, 2018)
Southern Trust Insurance Company v. Mountain Express Oil Company
828 S.E.2d 455 (Court of Appeals of Georgia, 2019)
City of Dublin School District v. Mmt Holdings, LLC
830 S.E.2d 487 (Court of Appeals of Georgia, 2019)
Georgia Interlocal Risk Management Agency v. Godfrey
614 S.E.2d 201 (Court of Appeals of Georgia, 2005)

Cite This Page — Counsel Stack

Bluebook (online)
LOUISE ROYAL v. GEORGIA SCHOOL BOARDS ASSOCIATION RISK MANAGEMENT FUND, Counsel Stack Legal Research, https://law.counselstack.com/opinion/louise-royal-v-georgia-school-boards-association-risk-management-fund-gactapp-2022.