## Facts

- A fifth-grade student, Richard Simonetti, returned from recess and was struck in the left eye by a pencil propelled from a classmate’s hand when the classmate tripped.
- During recess, three students (including the classmate) were required to remain in the classroom as punishment for earlier misbehavior.
- The teacher supervised the three students during recess, then instructed them to take their seats.
- The teacher stepped to the classroom doorway/hallway area to monitor other students returning from recess and spoke with another teacher.
- Simonetti and his mother sued the School District of Philadelphia, alleging negligent failure to provide adequate classroom supervision.
- After a nonjury trial, the court entered judgment for plaintiffs totaling $15,000; the School District appealed.

## Issues

1. Whether the evidence supported a finding that the School District, through its teacher, breached a duty of reasonable supervision by briefly standing at the classroom doorway while students returned from recess.
2. Whether the pencil injury resulted from a foreseeable risk that required additional or different supervision.

## Decision

- The Superior Court reversed the judgment for plaintiffs and entered judgment for the School District.
- The court held that, even viewing the evidence favorably to plaintiffs, the teacher’s conduct constituted reasonable supervision under the circumstances.
- The court concluded the accident was not shown to be reasonably foreseeable such that the teacher’s brief positioning at the doorway amounted to negligence.

## Legal Principles

- Appellate review after a nonjury trial is limited to whether factual findings are supported by competent evidence and whether the court committed an error of law.
- Proper student supervision is circumstance-dependent; the duty is reasonable care, not constant, uninterrupted physical presence.
- A teacher and school district are not insurers of student safety; liability requires an unreasonable supervisory lapse in light of foreseeable risks.
- Injuries caused by sudden, accidental student acts, without warning signs of a specific danger, generally do not establish negligent supervision based solely on a teacher’s brief, nearby absence.

## Conclusion

The court held that a teacher who instructed students to sit and temporarily supervised from the classroom doorway while other students returned from recess acted reasonably, and the school district was not liable for an unforeseeable injury caused by a classmate’s accidental trip that propelled a pencil into another student’s eye.


Simonetti v. Sch. Dist. of Phila., 308 Pa. Super. 555, 454 A.2d 1038 (Pa. Super. Ct. 1982)