In I.C. v. Compton Unified School Dist., ordered published February 6, 2025, the Second District Court of Appeal, Division 8 affirmed a judgment entered after jury trial. The 16-year-old plaintiff and his friend started a fist fight during an art class. Their teacher intervened. The teacher weighed 375 pounds, and had recently been using a walker because of a back condition. While pulling the larger boy away from the plaintiff, and while plaintiff was hitting the teacher, the teacher lost his balance and fell on the plaintiff's leg, causing a severe fracture. The incident was captured on video. The plaintiff sued the teacher and the school district for negligence. He contended the teacher should not have stopped the fight, and instead should have prevented it, and that the school district failed to adequately train the teacher in safely intervening in student fights. The court rejected expert witnesses from both sides. The court also declined to give multiple instructions the plaintiff requested regarding duty. The jury assigned 50% fault for the injury to the plaintiff and 50% to the other boy, and found that neither the teacher nor the district was negligent.
The appellate court rejected the plaintiff's arguments of error. It affirmed the trial court's denial of JNOV to the plaintiff, finding substantial evidence supported the jury's conclusion that neither the teacher nor the district was negligent. The plaintiff's contentions that there was insufficient evidence that the district's training was reasonable and that the teacher acted with due care assume that the burden was on the defendants to prove lack of negligence. But the plaintiff had the burden to prove negligence. Plaintiff's contention that the jury had to be instructed on the nature of the special relationship between student and teacher, the duty of school authorities to supervise children and enforce rules, the standard of care for school employees, the duty of school authorities to train and supervise employees, the duty of school personnel to use reasonable measure to protect students, and the foreseeability of the injury failed. None of the instructions was necessary to assist the jury in deciding whether the teacher breached his duty to use reasonable care to prevent harm to others. The jury was adequately instructed to decide how a reasonably careful person would have acted in the teacher's situation. Exclusion of the plaintiff's expert on intervening in fights was within the trial court's discretion, based on the evidence that the expert had no experience teaching or managing a classroom. Further, the jury watched the video, and did not need an expert to expound upon how the intervention happened and whether it was done safely.