Glankler v. Rapides Parish School Board

Jennifer Mangel was a kindergarten student at Nachman Elementary School (school). Mangel’s class of 78 students took a field trip to the Parents’ Park at Pinecrest State School, a facility owned by the Louisiana Department of Health and Human Resources (department) (defendant). Three full-time teachers and 11 parents supervised the trip. The park consisted of one and a half acres of land with 100 pieces of playground equipment. Among the installations were 47 swings. The metal two-person swings weighed 60 pounds, had seats placed at adult height, and hung from steel straps attached to posts anchored in concrete. For two weeks prior to the trip, teachers told the students not to run in front of or push the swings. The warnings were reiterated before leaving the school on field-trip day and again during the walking tour the class took at the facility. However, without a push, the children were physically incapable of swinging on the two-person swings due to seats’ height. During the field trip, Mangel pushed a friend on one of the two-person swings, which struck Mangel in the hip. The impact permanently damaged the growth plate in Mangel’s leg. Nancy Glankler (plaintiff), Mangel’s mother, filed suit against the department and the Rapides Parish School Board (school board) (defendant) in a Louisiana trial court. The trial court found the school board liable due to inadequate supervision because the court did not consider parents adequate supervisors. The department was found liable for the unreasonably hazardous conditions of the swings. The board and the department appealed to the Louisiana Court of Appeal.