Softball coach injury immunity ruling reversed by MN Supreme Court

The Minnesota Supreme Court has reversed a previous court decision regarding immunity over an injury to a 9-year-old during a softball practice, saying in part, "a school district’s softball coach is entitled to official immunity when the coach exercises significant, independent judgment and discretion over how to supervise a softball practice."

What we know

In May 2017, a 9-year-old student, then in third grade, participated in a softball practice organized by and held on the property of the Walker-Hackensack-Akeley school district that was supervised by its coaches.

The practice involved at least two coaches, who arranged at least two "stations" that included a batting station, with players practicing at each station.

While at the batting station, another player accidentally struck the player in the forehead with a softball bat, causing a "permanent bump on her forehead."

According to their defense, at the time of the accident, the coach, "did not know if another coach had eyes on the batting station," but was "satisfied that the coaches were adequately near the station, that the players were of the age and ability to do the batting activity without direct, eyes-on supervision at all times, and that in any moment that she or the other coaches could observe the station with a turn of the head."

Following the injury, a concussion protocol was followed, and the player’s parents were notified.

However, on Feb. 6, 2023, the child and her mother, Kathryn Kendrick, filed a complaint against the school district and coaches, alleging the injuries were "directly and proximately caused" by the coaches’ negligence while supervising the softball practice, and that the school district was liable.

The complaint sought a judgment against the school district of at least $50,000.

Appeal

The school district argued that Kendrick failed to notify the district, as required under Minnesota statute.

Even if Kendricks had properly notified them, the district was entitled to immunity, it argued.

To prove her assertions, Kendrick relied on the opinion of another softball coach to argue that the coaches should have supervised the softball practice differently. 

Throughout the court process, the school district challenged the district court’s denial of its motion for summary judgment, asserting it was entitled to "vicarious official immunity" based on the discretionary acts of its coaches in supervising the softball practice at which the student was injured.

The school district argued that it is entitled to vicarious official immunity because the coaches "exercised professional judgment and discretion by determining a level of adequate supervision of the softball practice" and that Kendrick's reliance on the opinion of another softball coach does not defeat the school district’s immunity defense.

Decision

The Minnesota Supreme Court ultimately ruled that in addition to the coach, vicarious official immunity should be extended to the school district under the circumstances of the case.

"The official immunity doctrine provides that a public official charged by law with duties which call for the exercise of [their] judgment or discretion is not personally liable to an individual for damages unless [they are] guilty of a willful or malicious wrong," the Court said as part of its ruling.