Name of Case: Sheehan v. St. Peter’s Catholic School
Legal Citation: 291 Minn. 1, 188 N.W.2d 868
Facts: Margaret Sheehan and Charles Sheehan took action against St. Peter’s Catholic
School for injuries sustained when student was struck by pebbles thrown by
another student during recess on a playing field. The accident occurred on the
morning of May 6, 1966, when one of Margaret’s teachers escorted twenty
eighth grade girls to an athletic field during morning recess. The children were
directed to sit on a pole or log on the third base line of a baseball field. The
teacher returned to the school building and did not appear until after the accident.
About 5 minutes after the teacher left, some of the boys waiting to bat began
pelting the girls with pebbles. Although the girls protested, the pebble throwing
continued for 3 to 4 minutes until Margaret was struck in the right eye, causing
her to lose the sight in her eye.
Legal Issues: Evidence in suit against St. Peter’s Catholic School made question for jury
whether presence of teacher during recess on the playing field would have
prevented student from suffering loss of eye. The Supreme Court held that in
order to recover damages, it was necessary only to prove that a general danger
was foreseeable and that supervision would have prevented the accident. The
plaintiff did not have to prove that the particular accident was foreseeable.
Decision of Courts: Trial Court
Margaret Sheehan was awarded $50,000 against St. Peter’s Catholic school for
injury to her eye. The defendant argued that the court should have submitted to
the jury the question of the plaintiff’s own negligence.
Supreme Court of Minnesota
The court affirmed that a general danger of leaving students on a playing field
was foreseeable and the lack of supervision was a proximate cause of the injury.
Basis for Decision: The court stated that it is the duty of a school to use ordinary care and to protect
its students from injury resulting from the conduct of other students where such
conduct would reasonably have been foreseen and could have been prevented.
Children act on impulsivity without thought of the possibilities of danger. It is
precisely this lack of mature judgment, which makes supervision so important.
The mere presence of an adult is normally effective to curb misbehavior.
Agree or Disagree: I agree with the decision. Negligence is the failure to exercise a reasonable
standard of care that results in harm or injury to another person. There are no
requirements of constant supervision of all student movement at all times, but
supervision would have most likely prevented the accident. The pebble throwing
continued for 3 to 4 minutes before the plaintiff was injured. Had the teacher
been present, he/she would have put a stop to the dangerous activity before the
plaintiff was hurt.