## Facts

- Darrin R. Jarreau, an 18-year-old high school football player, injured his wrist during the 1986 season when struck by another player’s helmet.
- Jarreau repeatedly reported wrist pain and swelling to the coaching staff, but he was not withheld from participation and continued playing.
- After the season, at Jarreau’s request, the team trainer referred him to an orthopedist; December 8, 1986 X-rays showed a non-union navicular fracture with cystic changes.
- Medical testimony indicated the cystic condition affected healing and that delayed treatment likely worsened the injury by extending recovery and limiting treatment results.
- Jarreau required two surgeries and extensive rehabilitation and was left with permanent limitations restricting vigorous manual labor.
- Jarreau sued the head coach, trainer, and the Orleans Parish School Board, alleging negligent failure to obtain timely medical treatment aggravated the injury.
- A jury found the coach and trainer negligent; the trial court also found the School Board liable for their negligence and for failing to adequately train coaching staff and failing to provide a physician at the game where the injury occurred.
- The trial court awarded $80,000 in general damages and $12,724.89 in medical expenses.

## Issues

1. Whether the tort claim was prescribed under Louisiana’s one-year delictual prescriptive period when suit was filed on October 30, 1987.
2. Whether the coach, trainer, and School Board breached duties to obtain timely medical evaluation and whether the delay was a cause-in-fact of aggravated injury.
3. Whether Jarreau bore comparative fault for continuing to play and not obtaining medical care sooner.

## Decision

- The appellate court held the claim was not prescribed because prescription began when Jarreau became aware of the injury’s extent after the December 1986 diagnosis; suit filed within one year was timely.
- The court affirmed findings that the coach and trainer were negligent in failing to promptly refer Jarreau for medical treatment despite persistent symptoms.
- The court affirmed the School Board’s responsibility for employees’ negligence and left undisturbed the trial court’s findings of the Board’s separate negligence in training and medical-game coverage.
- The court reallocated fault, finding Jarreau partially at fault, and reduced total damages by one-third; liability was otherwise affirmed.

## Legal Principles

- In delictual actions, prescription may be suspended until the plaintiff knew or reasonably should have known of the injury’s nature and its causal connection, including through later medical diagnosis.
- Coaches and athletic trainers supervising interscholastic athletics owe an affirmative duty to respond reasonably to repeated complaints of injury and to secure timely medical evaluation when symptoms persist.
- Causation may be established by evidence showing a reasonable possibility that delayed treatment worsened the condition, extended recovery, or limited treatment outcomes.
- A school board may be vicariously liable for negligent acts of employees committed within the course and scope of employment and may also incur direct liability for deficient training or medical support practices.
- Comparative fault may be assessed against an adult student-athlete who continues to play through persistent symptoms and delays seeking medical attention.

## Conclusion

The court held the athlete’s suit timely under the discovery rule, affirmed negligence-based liability against the coach, trainer, and school board for delayed medical referral and related institutional failures, and reduced the damages by one-third due to the athlete’s comparative fault in delaying treatment while continuing to play.


Jarreau v. Orleans Par. Sch. Bd., 600 So. 2d 1389 (La. Ct. App. 4th Cir. 1992)