Constantinescu v. Conejo Valley Unified School Dist

In Constantinescu v. Conejo Valley Unified School Dist. (1993) 16 Cal.App.4th 1466, a small lot was used as a place for parents to pick up their children after school. (Id. at p. 1468.) The lot became overcrowded and congested when cars were present, conditions were "chaotic," and the school district knew the lot was hazardous, particularly after it eliminated " 'staggered' " dismissal times and all children were dismissed from school at one time. There was no barrier between the curb and the area when the children waited to be picked up. A car driven by a parent picking up her children after school lurched forward and jumped the curb, injuring two children. The jury found the lot was in a dangerous condition for which the school district was liable, and the Court of Appeal affirmed. (Id. at pp. 1469-1470.) In doing so, it first noted that the district had a special relationship with its students and, as a result, it had a heightened duty to make the school safe, and that children were held to a lower standard of care than adults. (Id. at pp. 1472-1473.) It acknowledged that traffic congestion is ordinarily not a dangerous condition. (Id. at p. 1473.) However, the court concluded that in these circumstances, the district had helped create "traffic congestion that was particularly dangerous," and that a jury could reasonably conclude the area was dangerous within the meaning of section 830, particularly when a school district was involved. (Constantinescu, supra, 16 Cal.App.4th at pp. 1473-1474.)