Pratt v. Robinson, 39 N.Y.2d 554 (1976)

A school district’s duty of care to students using its busing services extends only to providing a safe, designated bus stop; it does not encompass ensuring the safety of students’ routes from the bus stop to their homes, provided the bus stop itself is safe.

Summary

This case addresses the scope of a school district’s duty of care to students who use its busing services. A seven-year-old girl was injured after leaving her school bus at a designated stop and being struck by a truck several blocks away while crossing a busy intersection on her way home. Her parents sued the city, school district, and bus company, alleging negligent planning of the bus route and stop location. The court held that the school district’s duty extends only to providing a safe bus stop and does not require ensuring the safety of the route from the bus stop to the student’s home, as the district’s custodial duty ends once the child is safely discharged at the designated stop.

Facts

Lorraine Pratt, a seven-year-old, was injured when a truck struck her while she was crossing Plymouth Avenue South at Columbia Avenue in Rochester, New York. She had disembarked from her school bus at a regular stop on Columbia Avenue and Seward Street. She then walked with her older brothers along Columbia Avenue towards her home. Her brothers, who usually escorted her, proceeded across Plymouth Avenue without ensuring she was with them. When they noticed she had lagged behind, they motioned for her to cross, and she was hit by a truck while doing so. The bus route was established as an accommodation as part of an enrollment plan which allowed children to attend schools outside their immediate neighborhood.

Procedural History

Lorraine’s claim against the truck driver and owner was settled for the insurance policy limit of $10,000. Lorraine and her parents then sued the city, school district, and bus company, alleging negligence in planning the bus stop location. The trial court dismissed the complaint against all defendants at the close of the plaintiffs’ evidence. The Appellate Division affirmed the dismissal. The case then was appealed to the New York Court of Appeals due to the division in the court below.

Issue(s)

Whether a school district is negligent for locating a bus stop in a way that requires a student to cross a dangerous intersection several blocks away from the bus stop while en route home.

Holding

No, because the school district’s duty of care extends to the safe discharge of the student at a designated bus stop, not to ensuring the safety of the route from the bus stop to the student’s home.

Court’s Reasoning

The Court of Appeals reasoned that negligence requires a breach of duty. No duty exists on the part of the school district to transport the plaintiff to a location from which she could walk home without crossing dangerous streets. The relevant statute, Education Law § 3635, mandates equal busing opportunities based on distance from the school, not on relative hazards in different children’s routes. The court emphasized that “the legislative yardstick is distance…and not hazard which involves a myriad of factors.” The statute specifically states that school districts are not required to furnish transportation directly to or from a child’s home. The court clarified the school’s common-law custodial duty: it exists while the child is in the school’s charge, stemming from the school’s physical custody. This duty ceases when the child is discharged at a safe, scheduled bus stop, after which the parent is free to resume control. The court distinguished cases where liability was imposed when injuries occurred during busing or from violation of statutes requiring safe street crossings at the bus stop. Here, the injury occurred several blocks away from the safe bus stop, with no violation of any specific statutory duty. While school districts must operate busing with due care, this does not extend to providing transportation from the bus stop to the student’s home; doing so would require the school system to undertake protection of students beyond the undertakings that were in fact made available. The court concluded that the school district’s decision not to provide a stop closer to the plaintiff’s home did not constitute a breach of duty.