Doe v. United States Youth Soccer

Jane Doe, a minor, was sexually abused by Fabrizio, her former soccer coach. Fabrizio, who had a prior conviction for battery against his spouse, pleaded no contest to continuous sexual abuse of a child and lewd and lascivious acts on a child under age 14, and was sentenced to 15 years in state prison. Jane Doe sued, alleging negligence and willful misconduct against the United States Youth Soccer Association, the California Youth Soccer Association, and West Valley Youth Soccer League. The trial court dismissed on the ground that the defendants had no duty to protect plaintiff from criminal conduct by a third party. The court of appeals reversed, holding that the defendants had a duty to conduct criminal background checks of all adults who would have contact with children involved in their programs. The court noted that the defendants knew that Fabrizio had violated rules and engaged in inappropriate conduct, but had not notified the parents and had allowed Fabrizio to continue to have access to the plaintiff. View "Doe v. United States Youth Soccer" on Justia Law