California Appellate Tracker

Doe v. United States Youth Soccer Assn., Inc.

February 28, 2017

Youth soccer league owes duty of care to child participants to perform criminal background checks on adult volunteers and employees, but no duty to warn or train the children or their parents about the risk of sexual misconduct.

A youth soccer league holds a special relationship to the children that enroll in its programs, requiring the league to take affirmative steps to safeguard the enrolled children. Also, the league owes the children a limited duty of due care to perform criminal background checks to weed out sexual predators from among the volunteers and employees it authorizes to work with the children in the sports programs it organizes. The foreseeability of harm to the children from sexual predators is sufficiently high to require this relatively minimal step to protect the children even though the league, itself, did not engage in morally blameworthy conduct. However, the league’s duty of care does not extend to warning or training the children or their parents of the risk of sexual misconduct. Requiring such a warning/training program would be too burdensome. The decision also holds that plaintiff did not allege any facts showing that the league engaged in any willful misconduct as it did not know or have reason to know of the wrongdoing leading to the suit.

California Court of Appeal, Sixth District (Mihara, J.); February 22, 2017; 2017 WL 706179

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Doe v. United States Youth Soccer Assn., Inc.

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