## Facts

- Brooke Rathnow, a 16-year-old high school student, was enrolled in a required Wellness class in Knox County.
- Her teacher, Jennifer (“Coach”) Allen, showed an American Red Cross first-aid video during class.
- The video included scenes using artificial blood, including a scene where an actor appears to cut his arm with an electrical circular saw.
- Allen testified that before showing the video she routinely advised students that it contained artificial blood and told them they could put their heads down and close their eyes if they felt uncomfortable.
- While watching the scene with artificial blood, Rathnow felt “faint and lightheaded and dizzy and nauseous.”
- Rathnow told classmates she felt nauseous, stood up, and asked Allen if she could go outside to get some cold air.
- Allen asked Rathnow if she was okay; Rathnow replied yes.
- Under school policy, the teacher had discretion to allow a student to step out of the classroom; Allen granted the request.
- Rathnow went outside, fainted, and fell to the ground, breaking a front tooth; part of the tooth became embedded in her lower lip.
- Rathnow required medical treatment and was left with a scar.
- Through her parents, Rathnow sued Knox County and the Knox County Board of Education, alleging negligent supervision under the Tennessee Governmental Tort Liability Act based on Allen’s decision to let her go outside alone.
- After a bench trial, the trial court entered judgment for Rathnow and awarded $30,000, finding Allen had notice that a student could react to the video and that Rathnow might be reacting, even if Allen could not foresee an actual fainting episode.
- The defendants appealed, and the Court of Appeals reviewed the video as part of its analysis.

## Issues

1. Whether Rathnow’s fainting and fall were reasonably foreseeable such that allowing her to step outside alone could be a proximate cause of her injuries, supporting negligence liability against the governmental defendants.

## Decision

- The Court of Appeals reversed the judgment for Rathnow.
- The court held the record did not support a finding that Rathnow’s fainting and resulting injuries were reasonably foreseeable to Allen under the circumstances.
- Because foreseeability was lacking, proximate cause was not shown and the negligence claim failed.
- In light of the reversal on liability, the court did not need to address the defendants’ arguments about the damages award.

## Legal Principles

- A negligence plaintiff must prove duty, breach, injury, cause in fact, and proximate (legal) cause.
- Proximate cause in Tennessee includes a foreseeability component: if the harm could not reasonably be anticipated, there is no proximate cause and therefore no negligence liability.
- Tennessee applies a proximate-cause framework that considers (1) whether the conduct was a substantial factor in causing the harm, (2) whether policy relieves liability based on how the harm occurred, and (3) whether the type of harm could reasonably be foreseen by a person of ordinary prudence.
- Teachers are not insurers of student safety; the standard is reasonable and ordinary care under the circumstances.
- Foreseeability is often a fact question, but an appellate court may decide it as a matter of law when the proof cannot support a finding that the harm was reasonably foreseeable.

## Conclusion

Rathnow v. Knox County held that, where a student reported nausea after a first-aid video, answered that she was “okay,” and was allowed to step outside for air, the teacher could not reasonably anticipate that the student would faint and suffer dental and facial injuries; without reasonable foreseeability, proximate cause was not established, so the county and school board were not liable.


Rathnow v. Knox County, 209 S.W.3d 629 (2006)