Field Trip Immunity Does Not Apply to a Community College’s Hosting of an Intercollegiate Athletic Event

 

This article is provided to ACSA by Lozano Smith, an ACSA Partner4Purpose

Community college districts are generally immune from liability for injuries sustained in the course of field trips and excursions under the California Code of Regulations, title 5, section 55220. However, in Anselmo v. Grossmont-Cuyamaca Community College District, an appellate court determined that such immunity does not apply to an injury sustained during an intercollegiate athletic tournament.

Background

In this case, a community college hosted an intercollegiate beach volleyball tournament at its campus. During the competition, a beach volleyball player, who attended a different community college district, was injured when she dove into the sand and hit her knee on a rock.

The student filed a complaint against the college, claiming that she was injured due to a dangerous condition that existed at the college's facility. The college sought to dismiss the case, contending that the field trips and excursions immunity under section 55220 applied.

The court disagreed with the college and concluded that section 55220 did not apply to this situation. The court determined that the college did not conduct the student's field trip or excursion (i.e., direct or manage the actual travel). Rather, it provided the sports facility that the student traveled to with her team. As the host of the intercollegiate athletic competition, the college had an ongoing responsibility to provide reasonably safe premises to all teams participating in the tournament, including the visiting beach volleyball players.

Takeaways

Field trips and excursions immunity has specific and limited application for community college districts. While the court did not expressly state that such limitations apply to immunity provided to K-12 school districts, it did note the similarities in the statutory immunity language for K-12 districts. Finally, this case highlights the importance of public entities maintaining their property in a safe condition.


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