Credit v. Richland Parish Sch. Bd.
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The Supreme Court granted certiorari to determine whether a "statement made or action taken" language in La. R.S. 17:439(A) precludes a cause of action against school employees for negligent acts of omission and to ascertain whether an action may be filed pursuant to La. R.S. 17:439(D) directly against a school employee for the negligent operation of a motor vehicle to the extent his or her liability is covered by insurance or self-insurance. Nakisha Credit, mother of Adrianne Breana Howard (Breana), sued on behalf of Breana's half-siblings and herself stemming from a fight Breana had on school grounds. Breana was involved in "an ongoing feud" with Courtney McClain. Breana was dropped off in the rear of Rayville High School after school had been dismissed for the day at Richland Career Center and began to walk home. Plaintiffs contend LeBaron Sledge instigated a fight between Breana and Courtney whereby the two girls began fighting on the sidewalk in the rear of the school. During the altercation, Breana was either pushed by Courtney or fell off the sidewalk, and was struck by an oncoming Richland Parish school bus. Breana died as a result of her injuries. Among other allegations, Plaintiffs' petition alleged Defendants the School District, State Farm Mutual Automobile Insurance Company, the school board's insurer, the school superintendent and the bus driver were negligent in a variety of ways by failing to supervise the children, failing to timely respond to the fight, and failing to adequately staff the bus area with teachers or school employees. Upon review, the Supreme Court reversed the appellate court's decision to hold that La. R.S. 17:439(A) precludes a cause of action against school employees for certain negligent acts, including acts of commission and acts of omission. The Court otherwise affirmed the court of appeal's ruling that La. R.S. 17:439(D) permits an action directly against a school bus driver for the negligent operation of a school bus to the extent the driver’s liability is covered by insurance or self-insurance.
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