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Munn v. The Hotchkiss School

Connecticut Supreme Court

165 A.3d 1167 (2017)

Relevant factsFree

Fifteen-year-old Cara Munn (plaintiff) contracted tick-borne encephalitis, resulting in permanent brain damage, on a school-organized trip to forested regions of northeastern China with the Hotchkiss School (defendant); the school's pre-trip materials discussed immunizations and unrelated health topics but never warned about insect-borne diseases, despite the international-programs director having personally viewed CDC guidance specifically recommending long sleeves, pants, and DEET repellent for exactly the tick-encephalitis-affected regions on the itinerary. Students instead hiked the affected mountain region in shorts and t-shirts, got lost, and sustained many insect bites; Munn developed encephalitis ten days later. She sued in federal court and won a $41.5 million verdict, and the presiding federal court certified two state-law questions to the Connecticut Supreme Court: whether the school owed a duty to warn about the disease risk, and whether the damages award required reduction.

IssueFree

Whether schools have a duty to use reasonable care to convey appropriate warnings and protect students from foreseeable risks of harm during school-organized activities, including educational trips abroad.

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