Background graphic
Legal Updates

School district not liable for negligent supervision of childcare employee absent actual or constructive knowledge of employee’s actions

December 19, 2025

Rancho Cucamonga Central School District v. Superior Court (Flowers) (Nov. 7, 2025 E084855) 2025 WL 3471360

Plaintiff alleged that a school district’s child care employee sexually abused her. The trial court denied summary adjudication for the school district on plaintiff’s claim of negligent failure to supervise its employee. The school district petitioned for writ relief.

The Court of Appeal granted the writ petition. Citing C.A. v. William S. Hart Union High School District (2012) 53 Cal.4th 861, the court concluded that the District was entitled to summary adjudication of the negligent supervision of employee claim because plaintiff failed to provide evidence that any supervisor had actual or constructive knowledge of the employee’s inappropriate or abusive behavior.

Put Our Proven Appellate Expertise to Work for You.

For over 60 years, we've preserved judgments, reversed errors, and reduced awards in some of California’s most high-profile appellate cases.

Explore our practices Explore Careers
Horvitz