Koenig v. London
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The Supreme Court affirmed the judgment of the circuit court granting summary judgment to Bonnie London, the mother of person who shot plaintiff Sergeant John Koening of the South Dakota Highway Patrol, based on the events leading up to the shooting, holding that the circuit court did not err in granting summary judgment.
In underlying criminal case, Donald was convicted of aggravated assault against a law enforcement officer for shooting and injuring Koening. Plaintiffs - Sergeant Koening and his wife - brought negligence and loss of consortium claims against Donald and Bonnie. The circuit court granted summary judgment in favor of Bonnie, concluding that she did not owe a legal duty to control or supervise Donald, an adult, and should not be subject to liability for his criminal conduct. The Supreme Court affirmed, holding (1) Bonnie owed no duty to Sergeant Koening under a general negligence theory because she was not in a special relationship with Donald; and (2) Bonnie was not subject to a legal duty based upon her own conduct because it did not create a foreseeable high risk of harm.
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