Rathnow v. Knox County

Sixteen-year-old Brooke Rathnow (plaintiff) was viewing a first aid video in a wellness class at her high school when she became nauseous upon seeing artificial blood on the arm of one of the actors. Rathnow asked her teacher, Jennifer Allen, whether she could go outside for some fresh air. Allen asked whether Rathnow was all right, and Rathnow indicated that she was. Allen allowed Rathnow to go; however, while outside, Rathnow fainted and fell, breaking a tooth, which became lodged in her lower lip. Rathnow’s injury required medical treatment and left a scar. Through her parents, Rathnow filed suit against Knox County and the Knox County Board of Education (defendants), asserting that Allen was negligent for permitting Rathnow to go outside alone because her fainting was reasonably foreseeable. A trial court ruled in Rathnow’s favor, granting her $30,000 in damages. The trial court made findings that Allen was on notice that (1) a student could have a reaction to seeing the video; (2) Rathnow might possibly be having a reaction, because she asked to go outside; and (3) although Allen could not foresee that Rathnow would faint, she was on notice that Rathnow might feel faint. Knox County and the Knox County Board of Education appealed, asserting that it was not foreseeable that Rathnow would faint. The appellate court reviewed the video in question and rendered its ruling.