When do university instructors owe duties of care to students? Cope v. Utah Valley State College Explained

In Cope v. Utah Valley State College, the Utah Court of Appeals clarified when special relationships arise between university instructors and students, creating duties of care that overcome the public duty doctrine’s general immunity for governmental actors.

Background and Facts

Shawnna Cope was injured while practicing a ballroom dance lift as a member of Utah Valley State College’s dance team. The instructor had identified that Cope and her partner were performing the lift incorrectly—over the right shoulder instead of the left—and warned them to either perform it correctly or have it removed from their routine. When the couple attempted the more difficult left-shoulder lift without spotters, the partner lost his footing and Cope fell, suffering head injuries.

Key Legal Issues

The central issue was whether a special relationship existed between the instructor and student that would create a duty of care despite the public duty doctrine, which generally protects governmental actors from tort liability. The court also addressed whether the trial court properly reconsidered its initial denial of summary judgment.

Court’s Analysis and Holding

The court established a three-part test for special relationships in university settings: (1) a directive given to a student (2) by a teacher or coach (3) within the scope of the academic enterprise. Unlike the situation in Webb v. University of Utah, where an instructor’s directive about walking on icy sidewalks was only tangentially related to the academic mission, here the dance instructor’s directive related directly to the ballroom dance program. The court found that students reasonably “relinquish a measure of behavioral autonomy” to instructors within their area of expertise, creating the necessary special relationship.

Practice Implications

This decision significantly expands potential liability for university instructors in academic settings. The court’s categorical approach means that any course-related directive may create a duty of reasonable care, though questions of breach and proximate cause remain fact-intensive. The dissent warned this approach “significantly undercuts the protection afforded to state university instructors under the public duty doctrine.” Practitioners should carefully analyze whether instructor conduct falls within the academic enterprise when evaluating potential claims against educational institutions.