J.P. v. Carlsbad Unified Sch. Dist.
Annotate this CaseA jury found defendant Carlsbad Unified School District (CUSD) liable for negligently supervising an elementary school teacher, Raymond Firth, who sexually molested plaintiffs J. P. and E. B. The jury awarded the minors economic and non-economic damages. After entering judgment on the jury's verdict, the trial court denied CUSD's motions for judgment notwithstanding the verdict and for a new trial. CUSD argued on appeal that the court erred in denying its motion for judgment notwithstanding the verdict (and its earlier motion for nonsuit) because: (1) the minors did not file a government claim with the CUSD within the required six-month period; and (2) the evidence did not support the minors' argument that CUSD was equitably estopped from enforcing this limitation. CUSD also argued the court erred by providing incorrect jury instructions, and an insufficient special verdict form on the issue of equitable estoppel. CUSD further contended the court erred in denying its motion for a new trial because the evidence did not support the jury's award of future economic damages to the minors. In affirming the trial court's judgment, the Court of Appeal concluded the evidence supported the application of equitable estoppel and there were no other reversible errors.
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