## Facts

- A 15-year-old student at a Connecticut boarding school participated in a school-organized educational trip to China in July 2007.
- During a hike at Mount Panshan, a forested area near Tianjin, students were permitted to descend in small unsupervised groups; the student’s group became lost and was exposed to insect bites.
- The student contracted tick-borne encephalitis (TBE), a viral disease affecting the central nervous system, causing permanent neurological injuries, including loss of speech and cognitive deficits.
- Trial evidence showed school personnel reviewed CDC travel information before the trip warning that TBE occurred in the forested region to be visited and that insect-bite precautions could reduce risk.
- Plaintiffs claimed the school negligently failed to warn students and parents about TBE, failed to require or ensure use of insect repellent and other protective measures, and failed to provide adequate supervision during the hike.
- After a seven-day jury trial, the jury found the school solely liable and awarded $10.25 million in economic damages and $31.5 million in noneconomic damages (total $41.75 million).
- The school filed post-trial motions seeking judgment as a matter of law, a new trial, and alteration of the judgment (collateral source issues).

## Issues

1. Whether the evidence was legally insufficient to establish foreseeability of the student’s TBE infection and thus duty and breach.
2. Whether the evidence was legally insufficient to establish causation, including whether plaintiffs had to identify the precise location or moment of infection.
3. Whether the court’s rulings managing expert testimony required judgment as a matter of law or a new trial.
4. Whether the parents’ alleged comparative negligence required adjustment of liability or a new trial.
5. Whether the damages award was so excessive as to warrant judgment as a matter of law, a new trial, or remittitur.

## Decision

- The court denied the renewed motion for judgment as a matter of law under Rule 50(b).
- The court denied the motion for a new trial under Rule 59.
- The court denied the motion to alter the judgment as moot based on the parties’ stipulation regarding collateral source reduction.
- The court left intact the jury’s liability finding and the full $41.75 million verdict.

## Legal Principles

- In Connecticut negligence law, foreseeability supporting duty and breach is generally for the jury when reasonable factfinders could disagree, and a verdict stands if supported by sufficient evidence.
- Foreseeability does not require prediction of the exact injury mechanism; it is enough that harm of the general type was reasonably predictable from known or knowable risks.
- Proximate causation may be proved by circumstantial evidence; a plaintiff need not identify the precise moment or specific instrumentality (e.g., a particular tick bite) if the record supports a reasonable inference that defendant conduct was a substantial factor.
- Trial courts have broad discretion over admission, limitation, and sequencing of expert testimony; evidentiary disputes warrant a new trial only if the rulings were erroneous and harmful.
- Comparative negligence allocations are fact questions for the jury unless the evidence compels only one conclusion as a matter of law.
- A damages award should not be reduced unless it is grossly disproportionate or shocks the judicial conscience under governing remittitur standards.

## Conclusion

The district court upheld a jury verdict finding a school negligent for trip planning and supervision failures related to a known, preventable insect-borne disease risk, concluding that foreseeability, causation, comparative negligence, expert-evidence disputes, and the large damages award were all supported by the trial record and did not justify post-trial relief.


Munn v. Hotchkiss Sch., 24 F. Supp. 3d 155 (D. Conn. 2014)