Diamond Ranch Academy was a residential treatment center and therapeutic boarding school in Hurricane, Utah, for troubled youths between 12 and 18. Diamond Ranch’s staff included licensed physicians and healthcare providers.
Around October 2021, at the age of seventeen, T.G. was placed in Diamond Ranch by her parents. On December 9, 2022, T.G. reported to medical staff that she was experiencing back pain and having difficulty breathing. On December 13, 2022, the medical staff learned that T.G. had been vomiting and experiencing an elevated heart rate. T.G. continued vomiting for the next four days but was not referred to a medical doctor or taken to an off-site hospital. T.G. begged the staff to take her to the hospital, but her requests were denied. T.G. expressed anger at the staff for their failure to help her while she was sick. On December 20, 2022, T.G. was too sick to leave her bed but was still not referred to an offsite hospital. Later the same day, T.G. collapsed and an ambulance was called. T.G. then died of sepsis.
T.G.’s family sued Diamond Ranch, alleging false imprisonment and educational negligence, among several other claims. Diamond Ranch moved to dismiss these two claims.
False imprisonment occurs when there is an unlawful detention or restraint against another against their will. Diamond Ranch argued that the false imprisonment claim failed because T.G.’s parents approved T.G.’s admission to Diamond Ranch; did not allege that they tried to remove T.G. from Diamond Ranch; and did not allege T.G. was prevented from leaving Diamond Ranch’s premises by Diamond Ranch’s staff.
T.G.’s parents argued that Diamond Ranch made written representation to the students’ parents that Diamond Ranch would take care of the well-being of the students at the facility; T.G. was in pain and sick in December 2022 at Diamond Ranch; Diamond Ranch’s staff did not take her to the hospital when they learned she was sick and despite T.G.’s multiple requests; and T.G. had no ability to call her parents, order a taxi, or walk off the premises. T.G.’s parents further argued that Diamond Ranch restricted students’ access to communication with their parents; Diamond Ranch’s students endured behavior modification programs, which included labor and workshops; Diamond Ranch represented to parents that the students would be allowed to ensure their basic health needs; T.G. begged Diamond Ranch’s staff to take her to the hospital; and Diamond Ranch cancelled T.G.’s appointments to talk to her parents.
The Court dismissed the parents’ claims because they did not allege facts that Diamond Ranch committed an act that restrained T.G.’s movement against her will. For example, there was no evidence that T.G. tried to leave Diamond Ranch’s premises but was prevented by staff from doing so. The School declining to take T.G. to the hospital after she made requests was not enough to establish false imprisonment.
For the educational negligence claims, T.G.’s parents argued that Diamond Ranch committed educational negligence by failing to provide proper educational care to T.G.; fostering a culture of distrust and shame at Diamond Ranch; failing to provide constant care from a family practitioner; and failing to allow T.G. to talk to her parents on December 13, 2022. Diamond Ranch argued that the claim should be dismissed because Diamond Ranch was not responsible for educating T.G. In response, T.G.’s parents argued that educational institutions have a custodial duty to protect students when children are in their custody.
The Court dismissed the educational negligence claim because Utah does not recognize education negligence. Even if Utah recognized education negligence claims, the Court said it still would have dismissed the claim. While Diamond Ranch had a duty of care to T.G. because T.G. was in their custody, educational institutions do not breach any duty by providing a poor education, as T.G.’s parents alleged here. Furthermore, the Court found there was a reasonable dispute about whether Diamond Ranch’s education curriculum was the cause of T.G.’s death. For these reasons, the Court dismissed the educational negligence claim.
Note: This Court’s decision was only on two narrow claims, false imprisonment and educational negligence. This family has also brought other claims, including a general negligence claim, against the School. LCW will monitor this case for future developments.
Goodridge v. Diamond Ranch Acad., Inc. (D.Utah May 17, 2024) 2024 U.S.Dist.LEXIS 91351.