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Court Finds No Conspiracy Or Civil Rights Violations By School Administrators And Police Sergeant Following Deadly Car Accident Of Two Brothers
Two brothers, Z.K. and C.K., were driving to a basketball tournament for their school, Park Christian. The team drove in a three-car caravan: Park Christian’s assistant coach and head coach each drove a car of players, with Z.K. and C.K.’s car at the end. During the drive, the head coach cut off a semi-truck, and the semi-truck encroached into the next lane. To avoid a collision, Z.K. veered into the median, rolled, and crashed. Z.K. and C.K. both died in the accident and the truck drove off.
A Minnesota State Patrol sergeant arrived at the scene to investigate and prepared a Crash Reconstruction Report, which found that Z.K.’s interaction with the semi-truck caused the accident.
The parents sued the head coach and Park Christian for wrongful death in Minnesota state court. The jury found that the head coach was not negligent and the unidentified semi-truck driver was the sole cause of the accident. The parents moved for a new trial based on newly discovered evidence: that Park Christian coaches and administrators had personal connections with the police sergeant that led him to make false claims in his crash report and trial testimony. The state trial court denied the motion, the Court of Appeals affirmed the decision, and the Minnesota Supreme Court denied the parents’ petition for review.
The parents then brought claims under 42 U.S.C. Sections 1983 and 1985(2), alleging that the sergeant violated their constitutional rights and state laws and standards because his bias toward Park Christian corrupted his investigation of the crash and later testimony. The parents also brought a Section 1985(2) claim against Park Christian, school administrators, the coaches, and the sergeant, alleging that they had conspired to obstruct justice in the jury trial. The trial court dismissed their claims and the parents appealed.
Section 1983 provides an individual the right to sue state government employees for civil rights violations. The Court of Appeals ruled that the doctrine of collateral estoppel applied and barred the parents from bringing their Section 1983 claims. Collateral estoppel is the doctrine that prevents a person from re-litigating an issue.
The Court of Appeals ruled that the parents previously filed a motion before the state courts that alleged that there was a personal connection between the sergeant and Park Christian, which impacted the fairness and impartiality of the sergeant’s investigation and trial testimony. Their Section 1983 motion raised identical issues. The state trial court’s ruling on that motion was “on the merits” of the case and final because the trial court considered the relevant issues when denying this motion. The parents had the opportunity to litigate these claims fully and fairly when they deposed the school administrators before trial. They had the opportunity to uncover the relationship between Park Christian and the sergeant, but they did not take advantage of it.
Section 1985(2) protects individuals against conspiracies seeking to interfere with the administration of justice with the intent to deny equal protection under the law. The conspirators must have been motivated by a class-based, invidiously discriminatory animus to succeed on a claim under Section 1985(2). The parents argued that they were perceived by the Defendants as (1) “lacking religious zeal” and (2) they supported minority students at Park Christian by paying tuition for these students. The Court of Appeals ruled that neither of these classifications qualified as a protected class under Section 1985(2). A class must possess the characteristics of a discrete and insular minority, like race, national origin, or gender. The Court of Appeals affirmed the trial court’s ruling and dismissed the claims.
Kvalvog v. Park Christian School, Inc. (8th Cir., May 4, 2023) 2023 WL 3240217.
Note: This case illustrates that students driving to and from school events can carry risks. In this case, two other students were in Z.K. and C.K.’s car but recovered from their injuries. In California, there are limitations on when students can drive other students. For example, during the first twelve months after obtaining their driver’s license, a minor cannot transport other passengers under 20 years old unless a parent/guardian, a California driver 25 years old or older, or a certified driving instructor accompanies them.