Kristopher Flowers attended a middle school within the Rancho Cucamonga Central School District from sixth through eighth grade between 1999 and 2002. During that time, he participated in a before-and-after-school childcare program located on the school campus. The West End YMCA operated the program. West End YMCA employed Christine Johnson as the program director. Johnson did not work for the District.
Flowers alleged that during the 2001 to 2002 school year, Johnson repeatedly sexually abused him. He alleged that some of the abuse occurred on the school campus during program hours and that other abuse occurred at Johnson’s home. Flowers did not report the alleged abuse to any District employees while he attended the school. No District employee witnessed the alleged abuse nor observed conduct by Johnson that appeared abusive or inappropriate.
In November 2022, Flowers filed a lawsuit against Johnson, West End YMCA, YMCA USA, and the District. He brought claims against the District for negligence, negligent hiring and retention, negligent supervision or failure to warn, and failure to perform mandatory duties.
The District moved for summary judgment or, in the alternative, summary adjudication. The trial court dismissed the negligent hiring and retention claim and the failure-to-perform-mandatory-duties claim. The trial court allowed Flowers to proceed with his negligence claim based on the District’s supervision of students and supervision of Johnson.
The District petitioned the Court of Appeal for a writ of mandate. The Court of Appeal limited its review to the denial of summary adjudication on Flowers’s claim that the District was negligent in its supervision of Johnson. The Court of Appeal did not review the claim alleging negligent supervision of Flowers.
The Court of Appeal applied the California Supreme Court’s decision in C.A. v. William S. Hart Union High School District. Under C.A., a school district may be liable for negligent hiring, retention, or supervision of an employee if supervisory personnel knew or should have known of the employee’s dangerous propensities and nevertheless failed to act. Constructive knowledge may suffice, but it requires evidence that reasonably supports an inference that supervisory personnel should have suspected misconduct.
The Court of Appeal concluded that the undisputed facts did not show that the District had actual or constructive knowledge of Johnson’s alleged dangerous propensities. The undisputed facts showed that no District employee, let alone a supervisor, witnessed any of the alleged assaults or inappropriate behavior, and Flowers did not report them to anyone during his time at the middle school. There was also no evidence that any District employee observed anything that reasonably should have triggered suspicion of abuse to justify an inference of constructive knowledge.
The Court of Appeal contrasted the case with Roe v. Hesperia Unified School District, where school administrators observed a janitor engaging in policy-violating physical contact with students and escorting them into empty rooms. Those facts supported an inference of constructive knowledge. No comparable evidence existed in Flowers’s case.
The Court of Appeal rejected Flowers’s attempt to rely on the standard governing negligent supervision of students. That standard concerns whether school personnel exercised ordinary prudence in supervising students and allows liability for inadequate or ineffective supervision. The Court of Appeal explained that this standard did not apply because the only claim at issue on appeal involved alleged negligent supervision of Johnson, not supervision of students.
Because no evidence showed that District employees knew or reasonably should have known of Johnson’s alleged conduct, the Court of Appeal concluded that the District was entitled to summary adjudication on the negligent supervision claim.
The Court of Appeal granted the District’s petition for writ of mandate. It directed the trial court to vacate its prior order denying summary adjudication and to enter a new order granting the District summary adjudication on Flowers’s negligent supervision cause of action. The Court of Appeal awarded the District its costs on appeal.
Rancho Cucamonga Central School Dist. v. Superior Court (2025) 116 Cal.App.5th 718.
Note: Although this case turned on the District’s lack of actual or constructive knowledge of the alleged abuse, SB 848 significantly expands the proactive child-safety obligations of California schools going forward. While liability for negligent supervision still hinges on knowledge or reason to suspect misconduct, SB 848 reflects the Legislature’s expectation that schools take affirmative, documented steps to prevent and detect abuse. Schools should ensure that agreements with outside contractors address training practices and reporting structures that are aligned with these expanded statutory duties.