Under Tennessee law, universities and colleges often owe basic duties to their students to protect them from known harms. This is particularly true for students living in dorms on university campuses, where the universities often function as landlords and caretakers of the students. However, under basic negligence law, individuals, entities, and corporations cannot be held accountable to protect students against dangers of which they did not know or could not have known. A recent case in the Tennessee Court of Appeals looks specifically at whether the Tennessee Technological University was liable for hearing damage caused to a hearing-impaired student by dormitory fire alarms.
Lindsay Crutchfield was a hearing-impaired student who enrolled at TTU in the fall of 2011. She notified the university that she was hearing-impaired and requested to be able to live off campus in order to accommodate her disability. TTU denied the request and instead decided to install a special emergency system in Ms. Crutchfield’s dorm room to deal with her disability. The system, called SilentCall, would notify her in the case of a fire by shaking her bed and turning on strobe lights. The existing fire alarm system, which emitted a high-pitched noise, remained in her dorm room as well.
One morning, Ms. Crutchfield awoke to a very loud, high-pitched noise coming from her room. She believed it was from her SilentCall system and immediately got up and exited the building. She later learned that it had been a mistaken fire alarm in the dormitory and that the alarm had been going off for 15 minutes before she awoke. After the incident, Ms. Crutchfield noticed that her hearing had noticeably worsened and that she could no longer hear conversations with individuals. After a medical visit to her doctor, it was determined that she had sustained severe hearing loss.
Ms. Crutchfield sued the school for negligence, arguing that it had a duty to protect her as a hearing-impaired student, and that it had failed to meet that duty when it subjected her to a prolonged, high-level fire alarm and failed to provide for anyone to awake her and escort her from the dorm after she did not immediately respond to the fire alarm. She presented evidence from her doctor, a medical expert, that her recent hearing loss had likely been caused by a high-noise, sudden event. The case was heard by a commissioner for the State of Tennessee Claims Administration, which found that TTU was liable to Ms. Crutchfield for negligence. It held that TTU had a duty to provide special protections to Ms. Crutchfield, and it should have known that the existing fire alarm could cause additional harm to her already fragile hearing, and that it was at fault for the accidental fire alarm and the hearing injury that resulted. On this basis, it awarded Ms. Crutchfield almost a million dollars in damages.
TTU appealed. It acknowledged that it owed a duty to Ms. Crutchfield, but it argued that there was no way it could have known that the existing fire alarm system would be harmful to her ears. Previous students had not complained about the system, and Ms. Crutchfield had not forewarned the school about sensitivity to high-decibel noises. The Court of Appeals agreed and further found that the noise level of the fire alarm was not above legal levels, and Ms. Crutchfield had, in fact, slept through the first 15 minutes of the alarm. The Court of Appeals determined that TTU could not have foreseen the harm that the alarm would cause and was not under a duty to have prevented such a harm. Accordingly, it reversed the trial court’s decision.
While the rules for negligence may seem straightforward, these cases can often be surprisingly difficult to prove. If you have recently been a victim of an accident that you believe involved the negligence of another party, knowledgeable personal injury attorney Eric Beasley can help you evaluate the strength of your claim. For more information or to discuss the circumstances of your case, contact the Law Office of Eric Beasley today at 615-859-2223.
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