Rhaney v. University of Maryland Eastern Shore

880 A.2d 357, 388 Md. 585, 2005 Md. LEXIS 487
CourtCourt of Appeals of Maryland
DecidedAugust 15, 2005
Docket118, September Term, 2004
StatusPublished
Cited by34 cases

This text of 880 A.2d 357 (Rhaney v. University of Maryland Eastern Shore) is published on Counsel Stack Legal Research, covering Court of Appeals of Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rhaney v. University of Maryland Eastern Shore, 880 A.2d 357, 388 Md. 585, 2005 Md. LEXIS 487 (Md. 2005).

Opinion

HARRELL, J.

A damaged fishtank, a sucker punch from its owner, and the resultant broken jaw prompted this litigation initiated by *589 Anthony F. Rhaney, Jr., a .student at the time at the University of Maryland Eastern Shore (“UMES” or “University”). On 29 October 1998, Ennis Clark, another student enrolled at UMES, began moving his personal items from the randomly-assigned dormitory room that he shared with Rhaney into a different dormitory room. When Clark left the room, Rhaney moved Clark’s fish tank (which yet awaited transport to the new dormitory room) and noticed it began leaking. Clark returned as Rhaney was attempting to stop the leak. He demanded that Rhaney explain what happened to the fish tank. Clark punched Rhaney in the jaw after Rhaney denied repeatedly that he had cracked the fish tank as he moved it.

Clark had been disciplined once by UMES for fighting before the 29 October 1998 incident with Rhaney. He was involved in two altercations with other students, first at an on-campus party on 13 March 1998 and at a subsequent, related, fight at a campus dining hall on 14 March 1998. 1 UMES suspended Clark after he pled guilty before the Judicial Council of UMES to fighting and disorderly conduct regarding the 14 March incident. The University instructed Clark that the suspension could be lifted if he participated in “professional counseling related to conflict resolutions.” Thereafter, Clark attended a Save Our Streets (“S.O.S.”) program in Washington, D.C. and offered that experience in satisfaction of the school’s requirement for his re-admission. UMES, for better or worse, permitted Clark to return after receiving documentation of his participation in that program.

After the 29 October 1998 battery, Rhaney filed a complaint in the Circuit Court for Somerset County, alleging, among other things, two counts against UMES. 2 Count III pled that UMES either negligently failed to disclose to Rhaney Clark’s *590 dangerous tendencies or negligently assigned Clark to be Rhaney’s roommate. Count IV stated that UMES breached its duty to Rhaney under premises liability principles, alleging that Rhaney was a business invitee. UMES moved for summary judgment, arguing that UMES, as a landlord, did not violate a known duty to Rhaney as a business invitee or tenant and asserting that a special relationship (a pre-requisite to UMES owing a duty to control the conduct of a third party (Clark)) did not exist between UMES and Rhaney. The judge denied the motion. At the end of a trial, the jury returned a verdict against UMES.

UMES appealed to the Court of Special Appeals. Univ. of Md. E. Shore v. Rhaney, 159 Md.App. 44, 858 A.2d 497 (2004) (en banc) (hereinafter “UMES”). The Court of Special Appeals’s majority reversed the judgment of the Circuit Court, observing that there could be no breach of duty owed to Rhaney as a business invitee or tenant where the “evidence of Mr. Clark’s prior misconduct was insufficient to establish the foreseeability that he would assault the other person assigned to his dormitory room.” UMES, 159 Md.App. at 60, 858 A.2d at 506. The intermediate appellate court refused to address the special relationship theory interjected by UMES because it had not been alleged by Rhaney in his complaint as a theory of recovery. Id. at 47-48 n. 2, 858 A.2d at 499 n. 2 (citing Bourexis v. Carroll County Narcotics Task Force, 96 Md.App. 459, 478, 625 A.2d 391, 398 (1993)).

We granted Rhaney’s petition and issued a writ of certiorari, Rhaney v. University of Maryland Eastern Shore, 384 Md. 448, 863 A.2d 997 (2004), to consider the following questions:

I. Did the Court of Special Appeals err by imposing an incorrect standard of foreseeability of harm which unduly restricts causes of action against business hosts and landlords for their failure to protect invitees or tenants from criminal activity?
II. Did the Court of Special Appeals improperly inject into the case law of premises liability applicable to this case *591 its views of proper public policy regarding proper college admission, re-admission, and disciplinary procedures?

We also granted the conditional cross-petition of UMES possibly to consider the following:

III. Did the University owe a duty to protect Rhaney from the student who punched him when the University had not taken charge or custody of either student and when the University undertook no affirmative act to protect Rhaney upon which Rhaney could reasonably rely?

We are persuaded to affirm the Court of Special Appeals’s judgment, but upon different grounds. Because Rhaney shall not prevail as to any of his questions properly raised in his petition for writ of certiorari, the question presented in UMES’s cross-petition shall not be reached or decided.

I.

A.

Clark matriculated initially at UMES in the fall of 1997 as a first semester freshman. After completing his first semester, he was involved in an on-campus altercation at the Student Development Center on the night of 13 March 1998. The fight re-erupted on the fourteenth of March in front of a campus dining hall. Clark and several others were detained by campus police; Clark and one other student were suspended as a result. The remaining students involved in the fracas received on-campus punishment.

Clark’s suspension was not necessarily infinite. UMES prescribed in a letter, dated 24 March 1998, that Clark could apply for readmission for the fall 1998 semester if he completed “professional counseling sessions related to conflict resolutions.” If he did so, Clark could be re-admitted under a one academic year probationary period — subject to immediate and indefinite suspension for any future disciplinary violations. According to a letter, dated 11 June 1998, from the UMES Vice President for Student Affairs, Clark’s participation in the *592 S.O.S. program 3 satisfied the counseling requirement attached to the March 1998 suspension, although the “one academic year” probationary period would remain in effect should Clark apply for re-admission. Clark applied for re-admission the same day; he was re-admitted on 29 June 1998.

After being randomly assigned as roommates, Clark and Rhaney co-existed peacefully until the October 1998 fishtank incident. 4 UMES did not inform Rhaney of Clark’s prior disciplinary decision, although Rhaney testified that he knew of the March 1998 incident within a few weeks of the start of the fall semester. 5

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880 A.2d 357, 388 Md. 585, 2005 Md. LEXIS 487, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rhaney-v-university-of-maryland-eastern-shore-md-2005.