## Facts

- Sanjay Jain, an 18-year-old freshman at the University of Iowa, lived in a university dormitory (the Mayflower) and began experiencing academic and personal difficulties, including drug and alcohol use.
- He was involved in dorm disciplinary incidents, resulting in probation and required alcohol/drug education classes; his parents were unaware.
- On November 20, 1994, resident assistants responded to a dispute and were told Sanjay intended to commit suicide by carbon-monoxide poisoning using a moped in his room; Sanjay acknowledged the attempt but said he would seek counseling.
- The next day, hall coordinator Beth Merritt met with Sanjay, offered counseling resources, provided her personal phone number, and asked him to call if he felt like hurting himself; Sanjay said he would seek counseling and talk to his family over Thanksgiving break.
- Merritt requested permission from a supervisor to notify Sanjay’s parents; the supervisor denied the request. Although evidence suggested an unwritten practice of notifying parents after suicide attempts, no report was sent to the dean’s office until after Sanjay’s death.
- After Thanksgiving break, Sanjay returned, again brought the moped into his room, and died by suicide from carbon-monoxide poisoning.
- Sanjay’s father, as estate administrator, sued the State of Iowa (through the University of Iowa) for wrongful death, alleging negligence in failing to protect Sanjay and failing to notify his parents.

## Issues

1. Whether a public university owes a common-law duty to protect an adult student from self-inflicted harm when staff know of a prior suicide attempt.
2. Whether the university owed a duty to notify the student’s parents of the suicide attempt.
3. Whether an unwritten parent-notification practice, confidentiality rules, or the university’s response to the incident created a legally enforceable duty sufficient to support a wrongful-death claim.

## Decision

- The Iowa Supreme Court affirmed summary judgment for the State of Iowa.
- The court held the university owed no legal duty to prevent Sanjay’s suicide.
- The court also held the university owed no legally cognizable duty to notify Sanjay’s parents of his earlier suicide attempt under the circumstances.
- Because duty was absent as a matter of law, the wrongful-death negligence claim failed.

## Legal Principles

- The existence of a duty in negligence is a question of law for the court.
- Absent a recognized special relationship involving custodial control, there is generally no affirmative common-law duty to protect another from self-inflicted harm.
- The relationship between a university and an adult student, without custodial control, does not by itself create a special relationship imposing a duty to prevent suicide.
- Federal student privacy law governing disclosure of educational records does not impose an affirmative tort duty to notify parents of an adult student’s mental health crisis.
- An informal or unwritten institutional practice of parental notification, without a specific undertaking creating reliance or control, does not create a legally enforceable duty to notify or to guarantee student safety.

## Conclusion

The Iowa Supreme Court concluded that, on these facts, the University of Iowa had no common-law duty to prevent an adult student’s suicide and no duty to notify the student’s parents of a prior attempt; summary judgment for the State was therefore proper.


Jain v. State, 617 N.W.2d 293 (Iowa 2000)