Yates v. Mansfield Bd. of Edn

In Yates v. Mansfield Bd. of Edn., 102 Ohio St.3d 205, 2004 Ohio 2491, 808 N.E.2d 861, the Ohio Supreme Court concluded that a board of education may be held liable when its failure to report the abuse of a student results in the abuse of another student. During the 1996-1997 school year, Amanda, a ninth grade student at Mansfield Senior High School, advised certain school officials, including the principal, that on three separate occasions her coach and teacher inappropriately touched her and made sexual comments to her. The principal investigated the claims and concluded that Amanda was lying. Her allegations were never reported and she was suspended for harassing her teacher. Id. at P2-3. Three years later, the same teacher sexually abused another student named Ashley. Ashley's parents filed suit claiming that the school failed to report Amanda's allegations of abuse and that Ashley was injured as a result. Ashley's parents also made a claim based on the negligent retention of the teacher. Id. at P5. In considering the applicability of the reporting requirement found in R.C. 2151.421, the Ohio Supreme Court stressed that the legislature designed the statute to promote the early identification of child abuse, stating that it, "clearly encouraged reporting and specifically discouraged the failure to report by imposing a criminal penalty." Id. at P23-24. It further stated that: "Because abused and neglected children lack the ability to ameliorate their own plight, R.C. 2151.421 imposes mandatory reporting duties on 'those with special relationships with children, such as doctors and teachers.' These persons, when acting in their official or professional capacity, hold unique positions in our society." Id. at P30. The Yates Court concluded that when school officials, "are informed that one of their schoolchildren has been sexually abused by one of their teachers, they should readily appreciate that all of their schoolchildren are in danger." Id. at P45. Thus, it concluded that a board of education can be held responsible for its failure to report abuse of a student that results in the subsequent abuse of another student by the same teacher. Id.