California Court Upholds Jury Verdict, Finds No Negligence in Teacher’s Intervention During Student Fight

I.C., then a 15-year-old student at Dominguez High School in the Compton Unified School District (District), was injured during a classroom fight. I.C. and a friend, C.L., began horse playing and slap-boxing in their art class when their teacher, Marco Godinez, saw them and told them to stop. The two students stopped briefly, but then began punching one another. Godinez attempted to intervene. During the struggle, Godinez lost his balance and fell onto I.C., breaking the student’s leg. The incident was captured on video by another student.

I.C. sued Godinez and the District for negligence, arguing that the teacher should not have intervened due to his weight (375 pounds) and physical condition. In particular, Godinez suffered from sciatica, had gone to the emergency room for back pain three days prior to the fight, and had been using a walker to get around.

I.C. also argued that the District failed to adequately train teachers on safe methods for breaking up student fights. The District provided training to teachers through its Non-Violent Crisis Intervention and Positive Behavioral Interventions and Supports programs, which focused on de-escalation techniques and maintaining a positive classroom environment. However, the District did not provide specific training on physical intervention or restraint techniques, instead allowing teachers to use discretion in handling student altercations.

After a 15-day jury trial, the jury determined that neither Godinez nor the District was negligent and assigned equal responsibility (50%) to I.C. and C.L. for the incident.

I.C. filed a judgment notwithstanding the verdict, which is a motion that asks the trial court to overturn the jury’s verdict on the grounds that no reasonable jury could have reached that conclusion based on the evidence presented. I.C. argued that the evidence did not support the jury’s conclusion that neither Godinez nor the District was negligent. I.C. argued that Godinez acted negligently by physically intervening in the fight despite his physical limitations and lack of training. He also contended that the District failed to properly train its teachers on safe intervention techniques, creating an unreasonable risk of harm.

The Court of Appeal disagreed and upheld the jury’s finding. The Court reasoned that:

• The jury reviewed the video evidence multiple times and concluded that Godinez did not act unreasonably.
• Witnesses, including another student involved in the fight, testified that Godinez fell accidentally while trying to protect the students from injury.
• The District’s training program, which focused on de-escalation and professional discretion rather than strict physical intervention techniques, was consistent with national education standards.

Since the jury’s verdict was supported by substantial evidence, the Court of Appeal concluded that the trial court properly denied the motion.

I.C. also argued that he should be given a new trial because the trial court erred by refusing to give special jury instructions emphasizing the special duty of care owed by schools to students. In particular, I.C. argued that schools have an affirmative duty to take reasonable steps to protect students, school authorities must provide adequate supervision and proper training to staff, and the District’s duty includes protecting students from foreseeable harm, even from third parties.

The Court of Appeal again disagreed. It reasoned that the jury was already properly instructed on negligence, including the duty of care owed by school personnel. The core issue was not whether the District had a duty to protect students (which was undisputed), but whether Godinez acted negligently, which the jury resolved in his favor. The Court found that the rejected instructions would not have changed the outcome since the standard of care was adequately covered by the instructions given.

Finally, I.C. argued that the trial court improperly excluded I.C.’s expert, Douglas Dickerson. The trial court excluded Dickerson because he lacked relevant expertise in teacher training and classroom management. The appellate court affirmed, noting that:

• Mr. Dickerson’s background was in law enforcement and juvenile delinquency, not in education policy or teacher training.
• His testimony would not have provided meaningful insight into how teachers should intervene in student altercations.
• The jury could evaluate the video evidence themselves without needing an expert to interpret what happened.

Additionally, the trial court also excluded the District’s expert on school safety policies, ensuring neither side had an expert advantage.

The California Court of Appeal affirmed the trial court’s ruling, rejecting all of I.C.’s arguments.

I.C. v. Compton Unified School Dist. (Jan. 15, 2025) ___Cal.App.5th___ [2025 Cal. App. LEXIS 62].)

Note: Although this case concerns a public school district, private schools also have a duty of care to protect students.