Safety Law News for January 27, 2023

— In North Carolina, the United States Court of Appeals upheld the dismissal of a teacher’s lawsuit against a school for injuries she received when she was physically attacked by a special education student when she was the only teacher in an inclusion class of 30 students.  The teacher specifically singled out the principal because the administrator was aware – as were others in the school – that the student was known to have been violent on prior occasions.  The court held that despite the Principal’s violation of school rules – school policy required that “when a class has ten of thirty students with (Individualized Education Plans (“IEPs”)), two teachers must be present,” – the teacher’s substantive due process claim failed as a matter of law.  The state-created danger doctrine…does not require governmental actors to affirmatively protect life, liberty, or property against intrusion by private third parties.”  The court held that, “the state-created danger exception applies only when the state affirmatively acts to create or increase the risk that resulted in the victim’s injury….[not] a failure to protect against a danger.”  Burns-Fisher v. Romero-Lehrer

— In West Virginia, the legislature is proposing a school safety policy that will allow teachers to serve as armed “School Protection Officers” in their buildings.  House Bill 2549, would permit each county to choose to decide it wants to place SPOs in its schools. Interested employees would have to obtain a concealed carry permit and undergo initial and then annual training and evaluations by the Department of Homeland Security.

— In Tennessee,  House Bill 127 would let school security officers restrain special education students.  The proposal is designed to protect students and teachers by “address[ing] an inconsistency in the law regarding who may use handcuffs, to secure special education students. As the law stands right now, school resource officers are allowed to use mechanical restraints but not school security officers.

— In Michigan, students in East Lansing High School students walked out of class to protest increasing incidents of violence in the school and inaction by the Board of Education.  The students specifically requests that school officials install safety enhancements on campus and improve communications between the district and the community.