Rhea v. Grandview School District No. JT 116-200

694 P.2d 666, 39 Wash. App. 557, 1985 Wash. App. LEXIS 2203
CourtCourt of Appeals of Washington
DecidedJanuary 15, 1985
Docket5866-2-III
StatusPublished
Cited by18 cases

This text of 694 P.2d 666 (Rhea v. Grandview School District No. JT 116-200) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rhea v. Grandview School District No. JT 116-200, 694 P.2d 666, 39 Wash. App. 557, 1985 Wash. App. LEXIS 2203 (Wash. Ct. App. 1985).

Opinion

Thompson, J.

— Claudine Rhea appeals the summary judgment dismissal of her survival and wrongful death action against Grandview School District.

The Grandview High School senior class held a meeting in the school gymnasium during sixth period on a school day prior to graduation in 1979. When their faculty adviser arrived, the meeting was already in progress and the stu *559 dents were planning an off-campus party to be held on June 4, 1979, a "release day" authorized for all graduating seniors. Upon hearing their plans to obtain beer for the event, the adviser admonished the students and reported the incident to the principal.

On June 4, certain members of the class attended the party at a Columbia River location east of the Tri-Cities. No school district employees were present. Bambi Judkins, 18 years old, was in attendance and allegedly joined others in the consumption of alcoholic beverages at the party. While driving her car home, she was killed instantly in a car-truck collision and at the time of her death Ms. Jud-kins had a blood alcohol level of .13 percent. Claudine Rhea, Ms. Judkins' natural mother, brought a negligence action against the District. The trial court granted the District's motion for summary judgment. We affirm.

A motion for summary judgment under CR 56(c) can be granted only if, after considering all facts and reasonable inferences from the facts in the light most favorable to the nonmoving party, the court finds there is no genuine issue as to any material fact and the moving party is entitled to judgment as a matter of law. Wilson v. Steinbach, 98 Wn.2d 434, 437, 656 P.2d 1030 (1982) (citing Barrie v. Hosts of Am., Inc., 94 Wn.2d 640, 642, 618 P.2d 96 (1980), and Yakima Fruit & Cold Storage Co. v. Central Heating & Plumbing Co., 81 Wn.2d 528, 530, 503 P.2d 108 (1972)). In determining whether the order of summary judgment is correct, we must engage in the same inquiry as the trial court. Zehring v. Bellevue, 99 Wn.2d 488, 493, 663 P.2d 823 (1983), vacated on other grounds on reh'g, 103 Wn.2d 588, 694 P.2d 638 (1985).

The first issue is whether the District breached a duty to Ms. Judkins and can be held liable for negligence. The common law rule of tort immunity of school districts and their employees was abrogated in Washington by RCW 4.08.120:

An action may be maintained against a county or other of the public corporations mentioned or described in *560 RCW 4.08.110 [any county, incorporated town, school district or other public corporation of like character], either upon a contract made by such county, or other public corporation in its corporate character and within the scope of its authority, or for an injury to the rights of the plaintiff arising from some act or omission of such county or other public corporation.

The general effect of that statute is to render public corporations, school districts included, liable for their tortious acts or omissions according to the normal rules of tort law. Chapman v. State, 6 Wn. App. 316, 321, 492 P.2d 607 (1972).

A school district owes a duty to its pupils to "anticipate reasonably foreseeable dangers and to take precautions protecting the children in its custody from such dangers." Carabba v. Anacortes Sch. Dist. 103, 72 Wn.2d 939, 955, 435 P.2d 936 (1967) (quoting Tardiff v. Shoreline Sch. Dist., 68 Wn.2d 164, 170, 411 P.2d 889 (1966)); see also Briscoe v. School Dist. 123, 32 Wn.2d 353, 201 P.2d 697 (1949). Even when students are not in "custody" or compulsory attendance, Carabba, at 956-57, liability may nevertheless attach when schools supervise and exercise control over extracurricular activities. Sherwood v. Moxee Sch. Dist. 90, 58 Wn.2d 351, 363 P.2d 138 (1961).

When a school district's defense is that the off-premises activity was ultra vires, Coates v. Tacoma Sch. Dist. 10, 55 Wn.2d 392, 395-96, 347 P.2d 1093 (1960); Juntila v. Everett Sch. Dist. 24, 178 Wash. 637, 35 P.2d 78 (1934), the question becomes whether a tort was committed within the scope of the school's authority. Chappel v. Franklin Pierce Sch. Dist. 402, 71 Wn.2d 17, 20-24, 426 P.2d 471 (1967); Sherwood v. Moxee Sch. Dist. 90, supra at 360 (Hill, J., specially concurring). Chappel lists 10 factors in this determination 1 and states that the

*561 nexus between an assertion of the school district's authority and potential tort liability springs from the exercise or assumption of control and supervision over the organization and its activities by appropriate agents of the school district.
Where . . . the evidence reveals that educational and cultural values inhere in the normal activities of an extracurricular student body organization, and the school administration has assumed supervisory responsibility over the organization which, in turn, extends to tacit approval of and faculty participation in planning and supervising . . ., the school district cannot relieve itself of potential tort liability . . .

(Italics ours.) Chappel, at 24.

Here, no District employee or agent was present at the party or participated in any way with its planning. In fact, the faculty adviser expressly registered her disapproval of the students' plans. Nor can it be said the District's nonaction constitutes "tacit approval and faculty participation" in the activity. See Bradshaw v. Rawlings, 612 F.2d 135, 137, 140 (3d Cir.), aff'g in part, rev'g in part 464 F. Supp. 175 (E.D. Pa. 1979).

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694 P.2d 666, 39 Wash. App. 557, 1985 Wash. App. LEXIS 2203, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rhea-v-grandview-school-district-no-jt-116-200-washctapp-1985.