Horton
BOISE, Idaho (Legal Newsline) - The Idaho Supreme Court, in an opinion filed on Monday, affirmed the decision of a lower court that dismissed a wrongful death lawsuit that stemmed from the murder of a high school student.
The court sided with a school district that was sued over the death of student Cassie Jo Stoddart. In September 2006, two Pocatello High School students, Tory Adamcik and Brian Draper, murdered classmate Stoddart and were found guilty and sentenced to life in prison without the chance for parole.
Following the murder, the Stoddart family and the Contreras family, in whose house Cassie Jo was murdered, brought the suit, advancing claims against the Pocatello School District for wrongful death, negligent and/or intentional infliction of emotional distress and for property loss and loss of property value.
The families' claims are predicted upon the school district's alleged failure to take necessary action to protect Cassie Jo, despite warnings that Draper and another student planned a "Columbine-like" shooting.
The district court granted the school district's motion for summary judgment and entered judgment dismissing the action against the school district.
It found that because the murder occurred off school grounds and after school hours, the school district owed no duty to Cassie Jo at the time of her murder.
The district court further found that even if the school district had a duty to supervise Cassie Jo or her killers, the immunity afforded the school district by Idaho law would bar recovery.
Finally, it ruled that the school district would not be jointly and severally liable with the co-defendants for the damages suffered by the plaintiffs.
The families went on to appeal the decision of the district court regarding duty and immunity; they did not challenge the district court's determination regarding joint and several liability.
The Court, in its opinion authored by Justice Joel Horton, said the plaintiffs failed to demonstrate a duty owed to Cassie Jo.
Horton wrote, "In light of the lack of foreseeability of this crime and the enormous burden that would be imposed upon school districts if we were to find that a duty exists in this case, we conclude that no duty attached to the School District under these circumstances. Although we reach this conclusion, we do not suggest that the injury sustained in this case was 'minor.'
"We are fully conscious of the enormous loss suffered by the Stoddart family as a result of the brutal murder of Cassie Jo. Rather, despite the enormity of the harm involved in this case, our decision turns on the related considerations of foreseeability and the burdens a contrary decision would impose on school districts."
The Court also concluded that there was no "genuine issue of material fact" and that the danger to Cassie Jo was not foreseeable.
"There is nothing in the record that suggests that the School District received information during the 2004 investigation of Brian Draper's and (fellow student) C.N.'s threat of a Columbine-style shooting that would provide notice that two and a half years later one of the two students involved would commit a murder that was not, in fact, a school shooting, but rather a prelude to a planned Columbine-style attack," the Court wrote.
The Court said it is not suggesting that school districts have no duty to take appropriate action when school officials become aware of specific information that a student or students may be the target of a violent crime, even if that crime does not occur on school grounds.
"However, whatever duty the School District owed to its students in 2004 did not include the duty of indefinitely monitoring Draper, which is effectively what the Plaintiffs are now arguing," it wrote.
The Court affirmed the district court's grand of summary judgment dismissing the plaintiff's complaint. It also denied the parties' requests for attorney fees.
From Legal Newsline: Reach Jessica Karmasek by e-mail at jessica@legalnewsline.com.