In Schafer v. Oakwood Community Church, the Minnesota Court of Appeals affirmed summary judgment in favor of a church after a fourteen-year-old student suffered a serious head injury during a youth group gathering. The lawsuit arose after W.S. and another teenager, C.K., began playing a game to see who could kick each other the hardest while waiting for the youth meeting to begin. After each student kicked the other once, W.S. began following C.K., fell forward, and struck his head on the concrete floor. In the months following the incident, W.S. experienced headaches, dizziness, blurred vision, and was diagnosed with postural orthostatic tachycardia syndrome (POTS), which his parents alleged resulted from the incident.
At the time of the incident, approximately seven or eight teenagers were present, along with three adult youth leaders. One adult was preparing the lesson in the auditorium, another was working in an adjacent kitchen, and the pastor was moving between the lobby and auditorium greeting students. According to the record, the kicking game lasted roughly ninety seconds, and neither student sought adult assistance or otherwise drew attention to what they were doing.
W.S.’s parents sued the church for negligence, alleging that the adults failed to adequately supervise the students and that proper supervision would have prevented the injury. They also offered expert testimony opining that the church failed to exercise ordinary care, although the trial court ultimately excluded that testimony.
The Court of Appeals affirmed dismissal of the case because the church did not owe a legal duty to protect W.S. from this particular injury. The Court explained that negligence requires, among other things, the existence of a duty of care, and that duty is limited by the foreseeability of the harm. While organizations supervising minors must exercise ordinary care, they are not insurers of student safety and are not required to constantly monitor every student movement or anticipate every impulsive act of horseplay.
Applying Minnesota precedent governing supervision of students, the Court concluded that this incident was not reasonably foreseeable. Unlike prior cases where schools had notice of ongoing bullying, racial tensions, or repeated misconduct between particular students, there was no evidence that W.S. and C.K. had a history of conflict or that the adults had reason to anticipate the kicking game. The two boys had known each other for more than a year through youth group, and nothing suggested they posed a heightened risk to one another.
The parents argued that the church should have provided closer supervision because students sometimes roughhoused during youth group meetings. They also asserted that the students were effectively unsupervised at the time of the incident. The Court rejected those arguments, explaining that Minnesota law requires reasonable supervision, but not constant, eyes-on observation. The presence of three adult leaders supervising approximately eight teenagers constituted ordinary supervision under the circumstances, even though no adult happened to observe the brief kicking game before the injury occurred.
Accordingly, the Court affirmed summary judgment for the church on all claims.
Schafer v. Oakwood Cmty. Church (July 13, 2026, No. A25-1568) 2026 WL 2018644.
Note: This case may have resulted in a different outcome under California law. Nonetheless, for private schools, this case serves as a reminder that negligence claims can hinge on foreseeability. Maintaining appropriate supervision ratios, training staff to intervene when unsafe conduct is observed, and documenting prior incidents can all be important in defending claims arising from student injuries.