## Facts

- Joseph Goff, a 14-year-old student at Northwood High School in Caddo Parish, Louisiana, was known as mischievous but was not considered a serious discipline problem.
- Carter Bedford was a teacher at the school.
- While Bedford was speaking with two other teachers, Goff lightly hit Bedford in the back.
- Bedford told Goff to go to class.
- Goff responded by shooting Bedford in the face with a rubber band from short range and then ran away.
- Bedford threw a board at Goff as he ran, but missed, and Bedford returned to his classroom.
- About 15 minutes later, Bedford pulled Goff from class into an adjacent vacant room.
- Bedford struck Goff three to four times with his hand or fist, causing bruises to Goff’s chest, arms, and back.
- Goff’s mother, Anna Thomas, sued Bedford for battery and also sued the Caddo Parish school district and its liability insurer.
- The trial court found Bedford’s punishment greatly exceeded reasonable force but dismissed the suit on the theory that, because corporal punishment was legal in Louisiana, Bedford was immune from civil liability.
- Thomas appealed.

## Issues

1. Does a Louisiana teacher have categorical immunity from civil liability for corporal punishment simply because corporal punishment is permitted in schools?
2. If not, did Bedford’s corporal punishment exceed the bounds of reasonable disciplinary force (including in light of the time lapse between the student’s misconduct and the punishment) so as to constitute a tortious battery?

## Decision

- The appellate court rejected the trial court’s immunity rationale; the legality of corporal punishment does not eliminate civil liability for unreasonable or excessive force.
- The court held a teacher stands in the place of a parent for discipline and may use corporal punishment only to a reasonable degree.
- Considering the circumstances, including the interval between the provocation and the punishment, the court found Bedford’s blows were unreasonable and excessive.
- The court reversed the dismissal and held Bedford liable, with corresponding responsibility imposed on the school district and its insurer under applicable liability principles.

## Legal Principles

- A school teacher, while a minor is attending school, stands in the place of the parent for disciplinary purposes and may use a reasonable degree of corporal punishment.
- The authority to administer corporal punishment is a qualified privilege limited by reasonableness; it is not an absolute shield from tort liability.
- Corporal punishment that is unreasonable or excessive constitutes an actionable battery, even when corporal punishment is generally permitted by state law.
- A claim of provocation is weakened when there is time for reflection between the student’s misconduct and the teacher’s use of force; a “cooling-off” period supports treating later force as retaliatory rather than disciplinary.
- When a teacher’s wrongful conduct occurs in the course of employment, the employing school board and its liability insurer may be responsible for resulting damages.

## Conclusion

Thomas v. Bedford holds that Louisiana teachers are not immune from civil liability for corporal punishment: they may use physical discipline only to the extent it is reasonable under the circumstances. Because Bedford waited before taking the student aside and then struck him hard enough to cause bruising, the appellate court concluded the force exceeded reasonable discipline and reversed the trial court’s dismissal, imposing liability on Bedford and the school district and its insurer.


Thomas v. Bedford, 389 So.2d 405 (1980)