Doe v. Superior CourtAnnotate this Case
Woodhouse worked at a school run by Camp, but was terminated for inappropriate interactions with young girls. The incident was reported to Child Protective Services but no official action was taken. In 2006, Woodhouse was rehired. Camp staff had continuing concerns about Woodhouse’s behavior toward young girls. In 2007, a lifeguard noticed the girl, age nine, sitting on Woodhouse’s lap in the pool. Woodhouse was kissing her on the neck. The girl complained that “something [is] poking me in the butt.” Despite being advised not to hold children on his lap, Woodhouse was seen with the girl on his lap again. Camp determined there was no evidence of inappropriate touching. Woodhouse was terminated for failing to follow rules. Camp never disclosed the incident to parents or the police. Parents learned about the incident in 2013 through a police investigation of allegations that Woodhouse molested other children. Their complaint alleged that parents were not told that the girl was a victim (as opposed to a witness) until 2013. They filed suit. The trial court dismissed two claims, reasoning that while Camp may have had a special relationship sufficient to create a duty to prevent harm to children at Camp, “a duty to prevent harm is not the same as a duty to disclose.” The court of appeal reversed.