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Jain v. State9/7/2000
Appeal from the Iowa District Court for Johnson County, Lynn E. Brady, Judge.
Parent of student who committed suicide challenges summary judgment for university in action for wrongful death.
AFFIRMED.
Considered en banc.
This appeal concerns the tragic death of Sanjay Jain, a freshman at the University of Iowa. Sanjay committed suicide in his dormitory room. His father and administrator of his estate, Uttam Jain, sued the university for wrongful death, claiming it negligently failed to exercise reasonable care and caution for Sanjay's safety. In particular he claimed that if the university had followed its policy of notifying parents of a student's self—destructive behavior, the suicide could have been prevented.
On the university's motion for summary judgment, the district court dismissed Uttam's suit. It concluded the university owed no legal duty to Sanjay Jain to prevent him from harming himself, nor did it breach any legally recognized duty of care by failing to notify his parents of an earlier suicide attempt. For the reasons that follow, we affirm.
I. Background Facts and Proceedings
Sanjay Jain had just celebrated his eighteenth birthday when he enrolled as a freshman at the University of Iowa and moved into an off-campus university dormitory, the Mayflower. Sanjay came to Iowa from Addison, Illinois , the second of three children born to Uttam and Anita Jain. By all accounts they were a close-knit family.
Sanjay had enjoyed a successful academic career in high school and planned to major in biomedical engineering at the university. That course of study proved difficult. By the middle of the first semester his personal life as well as academic performance were showing the strain. He became moody and skipped many classes. He experimented with drugs and alcohol. In early November he was involved in an egg-throwing incident at the dormitory. He was penalized with three hours of compulsory community service. Soon after he was placed on one-year disciplinary probation for smoking marijuana in his room. Beth Merritt, the hall coordinator for the Mayflower dorm, imposed this discipline and ordered him to attend a series of alcohol and drug education classes.
Sanjay's parents and family were unaware of these difficulties. University policy calls for privacy with respect to the university's relationships with its adult students. Although Sanjay confided to his mother that he wished to switch his major from engineering to computer science, he told his father and brother that he liked biomedical engineering and his classes were going well. His frequent phone conversations with his parents were reportedly upbeat. Sanjay, in his father's words, described everything about college as "awesome."
In the early morning hours of November 20, 1994, resident assistants on duty at the Mayflower were called to a "domestic" dispute outside Sanjay's apartment. When they arrived they observed Sanjay and his girlfriend, Roopa, fighting over a set of keys to Sanjay's moped. Sanjay had moved the motorized cycle into his room. Roopa asserted that Sanjay was preparing to commit suicide by inhaling exhaust fumes and she was merely trying to stop him. Sanjay was interviewed independently. He, too, reported that he was trying to commit suicide. The RAs concluded from their conversation that Sanjay "had a lot of frustrations about family life and academics." After discussing the situation for about an hour, the group disbanded. Sanjay assured the RAs that he would seek counseling after getting a good night's rest.
Beth Merritt met with Sanjay the next day. He was reportedly evasive and refused
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