## Facts

- Katherine Rosen was an undergraduate student at UCLA.
- Another UCLA student, Damon Thompson, experienced paranoid delusions and auditory hallucinations after enrolling and believed other students were harassing him.
- UCLA administrators and campus mental-health professionals learned of Thompson’s mental health problems and he received evaluation and treatment through campus services.
- During a chemistry laboratory class on October 8, 2009, Thompson stabbed Rosen without warning, causing life-threatening injuries.
- Rosen sued the Regents and UCLA employees for negligence, alleging UCLA knew or should have known Thompson posed a danger and failed to take reasonable protective measures.

## Issues

1. Whether a university owes its students a duty of care to protect them from foreseeable violence by other students during curricular activities.
2. If such a duty exists, how its scope is limited (including what settings and activities it covers).
3. Whether the Regents were entitled to summary judgment on the theory that no duty exists as a matter of law.

## Decision

- The California Supreme Court reversed the Court of Appeal’s writ decision and remanded.
- The court held universities have a special relationship with their students that supports a duty to protect them from foreseeable violence during curricular activities.
- The court rejected a categorical rule that colleges owe no duty to protect adult students from other students’ criminal acts.
- The court emphasized the duty is limited and does not make universities insurers of student safety; liability still requires proof of breach, causation, and damages.

## Legal Principles

- Absent a special relationship, a defendant generally has no duty to protect another from third-party criminal acts; a special relationship can create a duty of reasonable care.
- A university’s relationship with its enrolled students can be a special relationship in settings where the institution controls the environment and students are required or expected to participate (e.g., classrooms and instructional laboratories).
- The duty recognized is confined to foreseeable violence in curricular activities (and activities closely related to the delivery of educational services), not all aspects of student life.
- Foreseeability and reasonableness limit the duty; the inquiry focuses on what the university knew (or should have known) and what reasonable steps were available under the circumstances.
- Recognizing duty determines only that a legal obligation may exist; breach and defenses (including any statutory immunities) remain fact- and context-dependent for further proceedings.

## Conclusion

The court held that universities owe a duty of reasonable care to protect students from foreseeable violence by other students during curricular activities, reversed the contrary writ decision, and returned the case for further litigation on breach and defenses.


Regents of Univ. of Cal. v. Superior Ct., 4 Cal. 5th 607 (Cal. 2018)