The Illinois Supreme Court has sided with Kankakee School District 111 and its employee, gym teacher Darren Wilbur Dayhoff, in a case involving a student injured during a soccer game in gym class. The court overturned a lower court decision, ruling that the defendants were protected by the Local Governmental and Governmental Employees Tort Immunity Act.
What Happened?
The case stemmed from an incident on March 13, 2017, when Riley Haase, a seventh-grade student, was injured during a gym class soccer game. According to the court documents, Riley was tackled by another student, identified as “Student A,” resulting in a severe arm injury that caused paralysis. The Haases filed a lawsuit, alleging that Dayhoff was negligent in his supervision of the class and that the school district was vicariously liable for his actions. The complaint alleged that Dayhoff was not properly supervising the class, as he was sitting in a corner on his laptop and phone. The complaint alleged that Student A had a history of violent behavior and that Dayhoff should have been more vigilant in supervising him.
The Lower Court’s Initial Decision
The circuit court of Kankakee County initially granted summary judgment to the school district and Dayhoff. The court determined that the defendants were immune from liability under sections 2-109, 2-201, and 3-108 of the Tort Immunity Act. Essentially, the court found that the school and Dayhoff were protected from liability because of the nature of their work and the type of negligence alleged.
The Appellate Court’s Reversal
The appellate court reversed the circuit court’s decision. The appellate court found that there were disputed issues of fact, particularly regarding Student A’s history of aggression and the school district’s knowledge of that history. The appellate court reasoned that if the district knew about Student A’s behavior and didn’t inform the teachers, that could potentially be considered “willful and wanton” conduct, which is an exception to the immunity provided by the Tort Immunity Act.
The Supreme Court’s Ruling
The Illinois Supreme Court disagreed with the appellate court and reinstated the circuit court’s decision, siding with the school district and Dayhoff. The Supreme Court found that the defendants were protected by section 3-108 of the Tort Immunity Act, which provides immunity for negligent supervision of activities on public property unless the conduct amounts to “willful and wanton” conduct.
Key Arguments and Findings
The Supreme Court focused on the definition of “willful and wanton conduct” under the Tort Immunity Act, which is defined as “a course of action which shows an actual or deliberate intention to cause harm or which, if not intentional, shows an utter indifference to or conscious disregard for the safety of others or their property.” The court found that the facts, even viewed in the light most favorable to the Haases, did not meet this standard.
The court noted that the Haases’ complaint did not allege that the school district was independently liable for its own willful and wanton conduct, but only that it was vicariously liable for Dayhoff’s actions. The court also found that Dayhoff’s uncontradicted deposition testimony established that he was not aware of Student A’s disciplinary history, and there was no evidence to suggest that he should have been aware.
The court determined that the evidence presented supported a claim of negligent failure to supervise an activity on public property, for which section 3-108 provides immunity. However, the actions of Dayhoff did not rise to the level of “willful and wanton” conduct. The court emphasized that the Illinois legislature intended to immunize school districts from liability for the type of negligent conduct alleged in this case.
The Supreme Court’s decision means that the school district and Dayhoff are not liable for Riley Haase’s injuries.