Garza v. Delta Tau Delta Fraternity National

College student Courtney Garza died by suicide two months after allegedly being raped by a fraternity brother; her three-page note, written the day before her death, explained she could not cope with the trauma and said goodbye, but did not describe the circumstances of her impending suicide itself. Her family (plaintiffs) sued the fraternity, university, and others (defendants) for wrongful death, alleging failure to properly supervise fraternity activities and provide crisis intervention. The trial court ruled the note's critical portions admissible under the dying declaration hearsay exception, and the appellate court affirmed on interlocutory appeal before the Louisiana Supreme Court granted review.