5 N.Y.3d 430 (2005)

A university has a duty to adequately supervise students in its charge, and it can be held liable for foreseeable injuries resulting from a failure to do so.

Summary

This case concerns a university’s liability for injuries sustained by a student during an altercation at an off-campus party. The Court of Appeals considered whether the university had a duty to supervise student activities, particularly where alcohol was involved. The Court held that while universities are not insurers of student safety, they have a duty to exercise reasonable care in supervising students, especially when the university sponsors or controls the activity. The court found that there was a question of fact as to whether the university breached that duty, and whether that breach was a proximate cause of the plaintiff’s injuries.

Facts

The plaintiff, a student at the university, was injured during an altercation at an off-campus party. Alcohol was present at the party. The plaintiff sued the university, alleging negligent supervision.

Procedural History

The Supreme Court dismissed the claim. The Appellate Division reversed, finding the university could be liable. The New York Court of Appeals granted leave to appeal and affirmed the Appellate Division’s decision.

Issue(s)

Whether a university owes a duty of care to its students to supervise student activities, particularly those involving alcohol, and whether a breach of that duty can result in liability for injuries sustained by a student.

Holding

Yes, because a university has a duty to adequately supervise students in its charge and can be held liable for injuries resulting from a failure to do so when it sponsors or controls the activity and the injury is foreseeable.

Court’s Reasoning

The Court of Appeals reasoned that while universities are not insurers of student safety, they have a duty to exercise reasonable care in supervising students. This duty is heightened when the university sponsors or controls the activity, such as orientation events or organized parties. The court noted that universities are aware of the risks associated with alcohol consumption and student behavior, making such injuries foreseeable. The court emphasized that this duty to supervise must be balanced against the recognition that college students are adults capable of making their own decisions. The Court found that the determination of whether the university breached its duty and whether that breach was a proximate cause of the plaintiff’s injuries was a question of fact that should be determined at trial. The court noted that while a university is not expected to monitor every student activity, it must provide adequate supervision of activities it sponsors or controls, especially when involving alcohol. The court noted: ” Colleges must adequately supervise students in their charge, and they can be held liable for foreseeable injuries proximately related to inadequate supervision.”