Beul v. ASSE Int'l, Inc.
United States Court of Appeals for Seventh Circuit
233 F.3d 441 (2000)
ASSE (defendant), a foreign exchange program, placed 16-year-old German student Beul (plaintiff) with a Wisconsin host family, but its volunteer coordinator only met with Beul once in over four months and never spoke privately with her, despite federal regulations and industry standards requiring regular, meaningful contact to monitor student welfare. The host father raped Beul, and the two entered an ongoing sexual relationship he threatened suicide over if disclosed; Beul missed 27 days of school, which went unnoticed by the coordinator until months later. After the relationship was discovered and Beul was removed, the host father was interviewed by police and committed suicide. A jury found ASSE 59% at fault for Beul's injuries and awarded her a proportional share of $1,100,000 in damages; ASSE appealed, challenging the sufficiency of proof of causation.
Whether a defendant that owes a duty to be a primary protector of the plaintiff against ordinarily unforeseeable injury may be held liable for causing that injury.