When do universities owe students a duty of care during field trips? Webb v. UofU Explained

In Webb v. UofU, the Utah Court of Appeals clarified when educational institutions owe students a duty of care, distinguishing between protective duties and instructional duties in university settings.

Background and Facts

James Webb was a University of Utah student required to attend an off-campus field trip to examine geological fault lines. During the trip, university instructors directed students to walk through a private condominium complex where sidewalks were covered with snow and ice. When a fellow student slipped and grabbed Webb for support, Webb fell and sustained injuries. The trial court dismissed Webb’s negligence claim against the university, concluding no duty of care existed absent a special relationship.

Key Legal Issues

The central issue was whether the university owed Webb a duty when directing students to traverse potentially dangerous terrain during required coursework. The university argued that without a special relationship, it had no duty to protect Webb from hazardous conditions.

Court’s Analysis and Holding

The Court of Appeals reversed, distinguishing Webb’s claim from the landmark Beach v. University of Utah decision. While Beach involved a student injured during voluntary, non-instructional activities, Webb was injured while following specific university directions during coursework. The court emphasized the crucial distinction between affirmative conduct (directing students to specific locations) versus mere failure to protect. When universities affirmatively direct students to engage in particular activities as part of educational instruction, they owe a duty to exercise ordinary and reasonable care.

Practice Implications

This decision provides important guidance for educational liability cases. Universities cannot escape duty simply by arguing they lack custodial relationships with students. When institutions provide specific instructions during required activities, they assume responsibility for exercising reasonable care. Practitioners should carefully analyze whether alleged negligence involves protective duties (requiring special relationships) or instructional duties (requiring only ordinary care standards).