The Colorado Court of Appeals has affirmed a lower court’s decision, declaring a case against STEM School Highlands Ranch (STEM) moot after the school deposited the maximum potential damages into the court’s registry. The case, brought by John and Maria Castillo, concerned the wrongful death of their son, Kendrick Castillo, who was killed in the 2019 STEM school shooting. The court found that because STEM had completed full discovery, deposited the maximum recoverable damages, and the Castillos sought no other form of relief, the case was properly dismissed.
Background of the Case
The Castillos filed a wrongful death lawsuit against STEM under the Claire Davis School Safety Act, seeking monetary compensation for their son’s death. The Act, passed by the Colorado General Assembly, aims to prevent school violence, compensate victims, and protect schools from unlimited liability. It also allows for “vigorous discovery” to uncover the causes of school violence.
STEM, a publicly funded charter school, moved to deposit $387,000—the maximum amount recoverable under the Colorado Governmental Immunity Act (CGIA)—into the court’s registry and requested the case be dismissed as moot. STEM did not admit liability.
The district court initially denied STEM’s motion, citing a provision in the Act that prohibits using procedural mechanisms to resolve a case before the completion of discovery. However, after extensive discovery, including depositions, document disclosures, and a site inspection, STEM renewed its motion. The district court then granted STEM’s motion, concluding the case was moot.
The Court’s Reasoning
The Court of Appeals upheld the district court’s decision, focusing on the specific circumstances of the case. The court cited the following factors:
* Completion of Discovery: The parties had engaged in “vigorous and full discovery,” as mandated by the Act. This included 21 depositions, the disclosure of over 25,000 pages of records, and the review of law enforcement investigations.
* Deposit of Maximum Damages: STEM had deposited the maximum amount of damages the Castillos could recover under the CGIA into the court registry.
* No Further Relief Sought: The Castillos sought only monetary damages and did not request any other form of relief, such as injunctive or declaratory relief.
The court referenced the case of *Rudnick v. Ferguson*, which established that a governmental defendant can render a case moot by depositing the maximum recoverable amount under the CGIA, even without admitting liability.
The Court of Appeals rejected the Castillos’ argument that they were entitled to a jury trial to determine STEM’s liability, stating that the Act does not mandate a trial in such circumstances. The court emphasized that the Act prioritizes full discovery and the provision of economic compensation, while also acknowledging the school’s right to limit its financial exposure.
Addressing the Castillos’ Arguments
The Castillos argued that the district court’s decision undermined the legislative intent of the Claire Davis School Safety Act, which they believed included providing a public forum for accountability. The court acknowledged the public interest in preventing school violence, but ultimately deferred to the legislature’s specific language in the Act.
The court also addressed the Castillos’ reliance on the *Scardina* case, which involved the Colorado Anti-Discrimination Act (CADA). The court distinguished *Scardina*, noting that CADA’s primary focus is not economic compensation, unlike the Claire Davis School Safety Act. Furthermore, the court emphasized the Act’s explicit provisions regarding discovery and settlement, which, in the court’s view, implicitly allow for a post-discovery resolution like the one in *Rudnick*.
The Castillos also claimed that the case should proceed because it fell under exceptions to the mootness doctrine, such as cases of great public importance, collateral consequences, and those capable of repetition yet evading review. The court dismissed each of these arguments, finding that none of the exceptions applied to this case.
Impact of the Ruling
The Court of Appeals’ decision clarifies the application of the Claire Davis School Safety Act, particularly regarding the balance between discovery, compensation, and the potential for a trial. The ruling confirms that if a school completes full discovery, deposits the maximum damages, and the plaintiffs seek only monetary relief, the case can be dismissed as moot, even without an admission of liability.