Stoddart v. Pocatello School District #25

239 P.3d 784 (2010)

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Stoddart v. Pocatello School District #25

Idaho Supreme Court
239 P.3d 784 (2010)

EL

Facts

High school students Brian Draper and Torey Adamcik murdered Cassie Jo Stoddart by stabbing her while Stoddart was visiting the Contreras family’s home. After a criminal trial, Draper and Adamcik were found guilty of Stoddart’s murder. The Stoddart family and Contreras family (collectively, the families) (plaintiffs) sued Draper and Adamcik’s Idaho school district (defendant), claiming the school district negligently failed to properly investigate allegations by other students of Draper’s violent tendencies. Over two years before Stoddart’s murder, the school district investigated claims that Draper was planning school shootings on two separate occasions. This investigation included interviews with Draper’s mother, Draper’s meeting with various school officials, interviews of Draper, psychological counseling referrals for Draper, and Draper’s ultimate transfer to an alternative school. On another occasion before the stabbing, a student told school staff about frightening, nonspecific notes referencing death in Draper’s locker. The families sued the district in state court, arguing that Stoddart’s killing was foreseeable to the school district because the district knew about Draper’s previous school-shooting plans, as well as the frightening notes in his locker. The families argued that the school district assumed a duty to continue investigating Draper once it started investigating his earlier threats. The school district filed a motion for summary judgment, claiming it was not responsible for a murder that occurred off-campus and after school hours. The state trial court granted the school district’s motion for summary judgment. The families appealed to the Idaho Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Horton, J.)

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