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Tindley v. Salt Lake City School District

5/17/2005

This appeal concerns the constitutionality of section 63-30-34 of the Utah Governmental Immunity Act, which limits the damages recoverable in actions against the state or its political subdivisions. Plaintiffs brought this action against the Salt Lake City School District (the "District"), asserting that the limitation violates both the Utah and the United States Constitutions. The District successfully moved for summary judgment. Plaintiffs appealed. We affirm.


BACKGROUND


David Smith was employed by the District as a teacher and debate team coach at Highland High School in Salt Lake City, Utah. Smith selected eight students, including Erin Anderson, Matt Ehrman, Brian and Jeff Horman, and Eric Sabodski, to compete in a debate tournament at the University of Southern California ("USC"). The tournament began on Friday, November 3, 2000, and concluded the following Sunday. Each student competing in the tournament paid a portion of the costs to attend, with the remaining costs paid by funds raised through the high school debate club.


Intending to drive the team to USC, Smith reserved a fifteen-passenger van from a rental agency. When Smith arrived at the rental agency, however, he learned that the van he had reserved was unavailable. Consequently, Smith rented two minivans to transport the students to the competition. District employee and assistant debate team coach Christian Bradley drove one of the vans, while Smith drove the other.


The debate team arrived at USC and participated in both the preliminary and the elimination rounds of the competition. Following the elimination rounds on Sunday afternoon, the team began the return trip to Salt Lake City. Bradley left at approximately 1:00 p.m., driving one of the rented minivans, with Eric, Jeff, Erin, Brian, and Matt as passengers. Smith followed shortly thereafter with the remaining students. Late that evening, while traveling through Millard County, Utah, Bradley lost control of the minivan due to his own negligence. The vehicle flipped several times, ejecting Eric, Jeff, and Erin.


Eric and Jeff were killed in the accident, and the remaining three students were seriously injured. Erin sustained numerous injuries, including a severe traumatic brain injury. Brian's injuries included crushed vertebrae and a fractured hand and foot, and Matt suffered an injury to his knee, as well as multiple contusions and abrasions. It is uncontested that plaintiffs' aggregate damages exceeded $500,000.


Recognizing its liability for Bradley's negligence, the District and its insurer, the Utah State Division of Risk Management, entered into a settlement agreement with plaintiffs Erin, Brian, Matt, and the parents and estates of Eric and Jeff. Under the settlement agreement, the District agreed to pay plaintiffs collectively $500,000, the maximum amount then recoverable under the Utah Governmental Immunity Act. In exchange, plaintiffs agreed to relinquish their rights to pursue any claims against the District or its employees, but reserved the right to challenge the constitutionality of the damage cap imposed by the Governmental Immunity Act.


In accordance with the settlement agreement, plaintiffs filed suit in district court, alleging that the cap violates several provisions of the Utah Constitution, including the open courts clause, as well as the provisions guaranteeing due process, uniform operation of laws, and the right to recover damages for injuries resulting in death. Plaintiffs also alleged that the cap violates the equal protection guarantee of the United States Constitution.


The District filed a motion for summary judgment, urging the district court to

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