## Facts

- William Ayala, Jr., a 15-year-old student at a Philadelphia school, was injured in an upholstery class when his arm was caught in a shredding machine, resulting in amputation.
- The student and his father sued the Philadelphia Board of Public Education for negligence.
- The complaint alleged negligent failure to supervise the class, provision of the machine without proper safety devices, defective and dangerous maintenance of the machine, and failure to warn students of the danger.
- The Board did not litigate the negligence merits at the pleading stage and instead asserted governmental immunity as a complete bar to suit.

## Issues

1. Whether the common-law doctrine of governmental immunity barred a negligence action against a local governmental unit, including a school district.
2. Whether a court may abolish judicially created governmental immunity for local governmental entities in the absence of legislative action.

## Decision

- The Supreme Court of Pennsylvania reversed the dismissal of the action.
- The court abolished the common-law doctrine of governmental immunity for local governmental units, including municipal and quasi-municipal corporations such as school districts.
- The case was remanded for further proceedings on the negligence claims.

## Legal Principles

- Governmental immunity for local governmental units in Pennsylvania was a judicially created common-law doctrine and could be modified or abolished by the judiciary.
- Local governmental entities may be subject to tort liability on the same general basis as private parties unless the legislature provides otherwise.
- Traditional rationales for blanket immunity—protection of public funds and fear of excessive litigation—were insufficient to justify denying recovery for governmental negligence.
- The governmental/proprietary function distinction was rejected as an unreliable and inconsistent basis for determining local governmental tort liability.

## Conclusion

The court eliminated blanket common-law governmental immunity for local governmental units in Pennsylvania, permitting negligence actions against entities such as school districts and returning the case for adjudication on its merits.


Ayala v. Philadelphia Bd. of Pub. Educ., 453 Pa. 584, 305 A.2d 877 (Pa. 1973)