Narrative Opinion Summary
In this case, the personal representative of a deceased individual's estate appealed a summary judgment favoring the Washington Department of Corrections (DOC). The appellant contended that the DOC failed in its duty to supervise an offender with a known history of domestic violence, ultimately leading to the offender's commission of murder. The DOC's duty of care, rooted in the 'take charge' doctrine from the Restatement (Second) of Torts, § 319, was central to the case, with the primary question being whether the DOC exhibited gross negligence in its supervision. The trial court had granted summary judgment, dismissing claims of gross negligence and negligent infliction of emotional distress. However, the appellate court reversed this decision, determining that genuine issues of material fact existed regarding the DOC's actions, necessitating a trial. The court emphasized the need for juries to consider whether the DOC's conduct met the threshold of gross negligence, which involves failing to exercise even slight care. The court's decision underscores the nuanced nature of gross negligence, particularly in the context of community placement and supervision of offenders, thereby reinstating the claims for further judicial examination.
Legal Issues Addressed
Duty of Care under Restatement (Second) of Torts, § 319subscribe to see similar legal issues
Application: The court examined whether the Department of Corrections owed a duty of care to prevent harm caused by Scottye Miller, based on a special relationship between community corrections officers and offenders.
Reasoning: DOC's community corrections officers are bound by a 'take charge' duty regarding the offenders they supervise, established by the Washington Supreme Court in Taggart v. State.
Gross Negligence Standard in Community Placementsubscribe to see similar legal issues
Application: The case considered whether the DOC's actions in supervising Miller amounted to gross negligence, which would breach their duty under RCW 72.09.320.
Reasoning: The DOC and its officers breach their duty when they exhibit gross negligence in handling community placements.
Negligent Infliction of Emotional Distresssubscribe to see similar legal issues
Application: Harper's claim for negligent infliction of emotional distress required proving gross negligence rather than ordinary negligence, as dictated by RCW 72.09.320.
Reasoning: Harper's assertion that she could succeed on a negligent infliction of emotional distress claim based on ordinary negligence is incorrect.
Summary Judgment and Genuine Issues of Material Factsubscribe to see similar legal issues
Application: The appellate court found that unresolved factual issues regarding DOC's supervision of Miller precluded summary judgment.
Reasoning: The appellate court found that genuine issues of material fact regarding DOC's care in supervising Miller warranted a trial, leading to the reversal of the lower court's decision.