“Outside the School-Student Relationship” – Arizona Supreme Court Defines the Geographic Limits of a School’s Duty of Care
Commentary on PUSD 210 v. Hon. Sinclair / Lucero, CV-24-0307-PR (Ariz. Jul. 15, 2025)

Introduction

In Phoenix Union High School District No. 210 v. Hon. Sinclair/Lucero (“PUSD 210”), the Arizona Supreme Court confronted a tragic set of facts: a 14-year-old freshman, Christopher “CJ” Lucero, was severely injured when he jaywalked across a four-lane public street moments before the school day began. The question was not how tragic the event was, but whether the school district owed CJ any legal duty of care at the moment of his injury.

The Court’s unanimous opinion, authored by Chief Justice Timmer, establishes a clear boundary line: a public school’s affirmative duty to protect its students from harm ends once the student is beyond the school’s custody and control, and that duty is not resurrected merely because the student intends to enter the campus. In doing so, the Court refined Arizona tort doctrine governing “special relationships” and sharply limited earlier language suggesting a broader “ingress-egress” obligation. The decision reverses the trial court, vacates the court of appeals’ denial of relief, and remands with instructions to enter summary judgment for the district.

Summary of the Judgment

• No Duty Found. The Court held that the risk which injured CJ—jaywalking across a public roadway—“did not arise within the school-student relationship.”
• Geographic & Temporal Limits. A school’s special-relationship duty is “bounded by geography and time” and ends when the student leaves the school’s custody and control.
• Ingress/Egress Doctrine Narrowed. The mere act of traveling toward a campus entrance is insufficient to trigger a duty; the school’s responsibility attaches only to dangers originating on school property or risks created by the school itself.
• Summary Judgment Ordered. Because duty is a question of law and none existed, the Court instructed the trial court to enter judgment for the district.

Analysis

A. Precedents Cited and Their Influence

1. Dinsmoor v. City of Phoenix, 251 Ariz. 370 (2021)
   • Recognized the “school-student” special relationship but emphasized that it is limited to risks arising while the student is under the school’s supervision.
   • PUSD 210 relies heavily on Dinsmoor to articulate the “known and tangible risk” test and the “bounded by geography and time” concept.
2. Perez v. Circle K Convenience Stores, Inc., 564 P.3d 623 (Ariz. 2025)
   • Clarified that determining duty is a de novo legal question, and courts may consider undisputed facts solely to locate where the risk arose.
   • Provided the procedural lens through which summary judgment was reviewed.
3. Monroe v. Basis Schools, Inc., 234 Ariz. 155 (App. 2014)
   • Held that a school owed no duty to a student hit by a truck one block from campus; cited with approval to reinforce limiting principles.
4. Stephens v. Bashas’ Inc., 186 Ariz. 427 (App. 1996) & other ingress/egress authorities
   • Demonstrated circumstances where a duty can extend beyond the physical boundary when the landowner creates the off-premises risk (e.g., a dangerous loading-dock configuration).
   • Distinguished in PUSD 210 because the school neither owned the street nor engineered the risk.
5. Restatement (Third) of Torts § 40 (Special Relationships)
   • Supplies theoretical foundation for affirmative duties; repeatedly quoted to circumscribe those duties.

B. Legal Reasoning of the Court

1. Special-Relationship Framework.
   A school, like an innkeeper or common carrier, has an affirmative duty to protect because it exerts control and students are compelled to be there. However, this duty attaches only when the student is in fact within that custodial context.
2. Determining Where the Risk Arose.
   The Court emphasized a two-step inquiry:
   1. Identify the specific risk that caused harm.
   2. Ask whether that risk originated while the plaintiff was within the defendant’s custodial sphere.
   Applying this test, jaywalking on 59th Avenue was “a risk that exists everywhere along the routes students take from home to school” and not one created or controlled by the district.
3. Ingress/Egress Not Unlimited.
   While Dinsmoor spoke of a duty to provide safe ingress and egress, PUSD 210 confines that doctrine to hazards emanating from the configuration of the premises itself. A public roadway the school neither owns nor controls falls outside that concept.
4. Foreseeability Explicitly Rejected as a Duty-Trigger.
   Echoing Quiroz v. ALCOA Inc., the Court reiterates that foreseeability pertains to breach, not duty. The district’s knowledge that students jaywalked did not create a legal duty.
5. Policy Considerations.
   Imposing liability would effectively make schools (and by analogy, all landowners) insurers for pedestrian activity on adjacent public roads—responsibilities traditionally vested in municipalities. The Court declined to shift that burden.

C. Potential Impact of the Judgment

• Clarifies Tort Boundaries. Arizona schools and public entities now have a bright-line rule limiting liability for off-campus vehicular accidents involving students.
• Guidance for Risk Management. Districts may rely on this precedent when designing arrival/dismissal protocols, knowing that mere observation of risky behavior (e.g., jaywalking) does not, by itself, impose a tort duty.
• Influence on Landowner Cases. Though the case arises in the school context, the Court analogized to landowner/invitee situations, signaling a general reluctance to extend duties across public rights-of-way absent landowner-created hazards.
• Legislative Implications. Advocates concerned about student traffic safety may now focus on statutory or regulatory solutions (e.g., mandatory school-zone designations) rather than tort litigation.
• Template for Other Jurisdictions. States grappling with similar claims will likely cite PUSD 210 as persuasive authority on delimited school liability.

Complex Concepts Simplified

Duty of Care

The legal obligation to act (or refrain from acting) in a certain way toward another. Without duty, negligence claims fail at the threshold.

Special Relationship

Certain relationships (e.g., school-student, carrier-passenger) impose an affirmative duty to protect because one party has control over, and the other depends on, the custodian.

Custody and Control

Practical supervision or authority over an individual’s safety. For schools, it typically exists during school hours, on campus, or at school-sponsored events.

Ingress and Egress

The legal terms for entering and exiting a property. A landowner must not create or maintain conditions that make those paths unreasonably dangerous.

Summary Judgment

A procedural device that ends a case without trial when there is no genuine dispute of material fact and the movant is entitled to judgment as a matter of law.

Jaywalking

Crossing a street outside a crosswalk or against a traffic signal—an inherently risky act which, absent a special circumstance, lies outside a school’s duty to regulate.

Conclusion

PUSD 210 v. Sinclair/Lucero crystallizes Arizona’s rule that a school’s affirmative duty of protection does not follow a student onto public streets. Only when the risk is generated by the school’s own premises or activities—and while the student is subject to the school’s custody and control—does that special duty arise. By drawing this clear boundary, the Court aligns Arizona with the majority of jurisdictions, offers predictable guidelines for educators and insurers, and shifts policy debates about student traffic safety from courtrooms to city halls and state legislatures. The case thus stands as a pivotal precedent on the limits of institutional liability in tort law.