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Brown v. USA Taekwondo

483 P.3d 159 (2021)

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Brown v. USA Taekwondo

California Supreme Court
483 P.3d 159 (2021)

Facts

The United States Olympic Committee (USOC) (defendant) oversaw the national governing bodies for each sport in the United States, including USA Taekwondo (USAT) (defendant). To participate in USAT competitions, competitors were required to be members of USAT and train under a USAT coach. Yazmin Brown and multiple other teenagers (the athletes) (plaintiffs) trained under USAT coach Marc Gitelman (defendant). Gitelman sexually abused the athletes and was eventually convicted for his conduct. Seeking financial compensation, the athletes filed a tort suit against Gitelman, USAT, and USOC. Against USAT and USOC, the athletes alleged negligence, claiming that the organizations breached their duty to protect athletes from Gitelman’s abuse. USAT and USOC both moved to dismiss, arguing that they did not have a duty to protect the athletes from harm by third parties, such as Gitelman. The trial court agreed and dismissed the claims. The court of appeals reversed in part, finding that a special relationship existed between Gitelman and USAT, creating a duty to protect athletes from his conduct. In contrast, it found that there was no special relationship between USOC and Gitelman or the athletes and, consequently, that the dismissal of the claim against USOC was appropriate. The California Supreme Court granted review.

Rule of Law

Issue

Holding and Reasoning (Kruger, J.)

Concurrence (Cuéllar, J.)

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