When does a university owe students a duty of care during field trips? Webb v. University of Utah Explained

The Utah Supreme Court’s decision in Webb v. University of Utah clarifies when educational institutions may face tort liability for student injuries during academic activities. The case addresses the intersection of governmental immunity and special relationships in the university context.

Background and Facts

James Webb, a University of Utah student, was injured during a required earth sciences field trip to examine fault lines at a condominium complex. While walking on icy sidewalks as directed by the instructor, Webb was knocked down when another student slipped and grabbed him for support. Webb sued the University, alleging negligence in directing students to traverse dangerous conditions during the curriculum-required activity.

Key Legal Issues

The central question was whether the University owed Webb a duty of care during the field trip. The court of appeals had found that the University’s affirmative act of directing students created such a duty, even without a special relationship. The Supreme Court considered whether governmental actors can be held liable for affirmative acts absent a special relationship and whether the facts established such a relationship.

Court’s Analysis and Holding

The Supreme Court reversed, holding that governmental actors are not liable for affirmative acts unless a special relationship exists. The court explained that while universities can create special relationships through actions that induce detrimental reliance, the directive to traverse the sidewalk was insufficient. The instruction was too tangential to the academic mission to reasonably induce reliance that would create the necessary special relationship.

Practice Implications

This decision reinforces that universities generally do not stand in loco parentis to students and are not insurers of student safety. However, the court left open the possibility that special relationships could emerge in circumstances involving greater loss of student autonomy or more significant peril. Practitioners should analyze whether university directives create reasonable detrimental reliance directly tied to academic success when challenging governmental immunity in educational liability cases.