Spears v. Jefferson Parish School Board

Justin Spears (plaintiff) was a kindergarten student at Woodland West Elementary School, part of the Jefferson Parish School System. Spears and his class were watching a movie in physical education class due to rain and were supervised by two coaches, John Brooks and Johnny Peyton. Spears and two of his friends began acting up, and Brooks called them over to sit near him. The boys continued acting up and Brooks warned them that he would kill them if the behavior continued. Brooks struggled to manage the three boys and took two of them to his office while he did paperwork. Spears remained behind and talked with Peyton. Brooks asked the two boys with him whether they wanted to pull a prank on Spears, and they agreed. Brooks led Spears to believe that Brooks had killed the two other boys, claiming that he hung them with a jump rope. The boys pretended to be dead on the floor, and Spears began to cry upon seeing them. The Spears family filed suit against the Jefferson Parish School Board (school board) (defendant) for injuries Spears suffered as a result of the incident. The family introduced evidence that Spears suffered mental and emotional trauma from the incident, making him fearful and anxious, regressing his psychological development, and requiring years of future therapy. Although Spears had been a well-adjusted child prior to the incident, he became unable to use the bathroom alone, testifying that he was afraid that Brooks would come out of the mirror to attack him. Spears also refused to go on family outings and became visibly uncomfortable whenever his mother left his sight. One expert attributed the symptoms to possible Post-Traumatic Stress Disorder. Both the family and the school board jointly stipulated that the school board was liable for the injury to Spears, and the matter went to trial on the issue of quantum meruit. The trial court ruled in favor of Spears and awarded the family $100,000 in general damages, $2,160 for future therapy, and $5,000 to each of the parents for loss of consortium. The school board appealed the damages to the Louisiana Court of Appeal, claiming that the trial court abused its discretion.