Yates v. Mansfield Board of Education

In 1997, Amanda, a ninth-grade student at Mansfield Senior High School (defendant), reported that Donald Coots, a coach and teacher at the school, sexually abused her. The school investigated, but no action was taken against Coots and the school did not report Amanda’s allegations to law enforcement or children’s services. In 2000, Coots sexually abused Ashley Yates (plaintiff), a 15-year-old student. The abuse was reported to the principal. Coots admitted to the abuse, was forced to resign, and was ultimately convicted of sexual battery. Yates’s parents (plaintiffs) sued the Mansfield Board of Education (Board) (defendant), arguing that the Board’s failure to report Amanda’s abuse allegations in 1997, despite being a mandatory reporter, was the proximate cause of Coots being able to abuse Ashley in 2000. The Board countered, arguing that it was a political subdivision entitled to sovereign immunity from any damages caused by its failure to report Amanda’s 1997 allegations. The trial court granted the Board summary judgment, holding that the Board was entitled to sovereign immunity. The appellate court affirmed, further holding that the Board’s failure to report Amanda’s abuse allegations only resulted in liability for Amanda’s injuries, not Ashley’s later injuries, because liability for failure to comply with mandatory reporting requirements did not extend to subsequent victims of the alleged abuser. The Yateses appealed.