2Ls and 3Ls
v.
The Tiny Staircase
77 U.Va 5 (2024)
Allard, C.J., delivers the opinion of the Court, in which Jones, Demitry, & Coco, JJ., join.
Coleman, J., dissents.
Allard, C.J., delivers the opinion of the Court.
This class action tort suit is brought before us by 2Ls and 3Ls who allege that they were falsely imprisoned by the new staircase in Slaughter Hall.[1] Plaintiffs contend that the stairway and doors are too narrow to accommodate the flow of students in between classes. It is so narrow, Plaintiffs claim, that it behaves “basically like a one-way street.” Pls.’ Aff. 1, para. 12.
The Tiny Staircase[2] filed a motion to dismiss for failure to state a petty claim. Tiny Staircase argues that no reasonable juror could find that it is too narrow to accommodate the Law School’s traffic. Tiny Staircase also notes that there are multiple access points to the second floor of Slaughter Hall. Tiny Staircase thus argues that, to the extent that there are traffic problems in the Tiny Staircase, Plaintiffs’ injury is self-inflicted, as an obvious alternative remedy exists. Finally, Tiny Staircase argues that Plaintiffs’ false imprisonment claim must fail because they were not completely confined but merely obstructed.
We are unpersuaded by all of Tiny Staircase’s arguments and accordingly deny their motion to dismiss.
I
As we noted in In re Staircase, the lovely original Slaughter Hall stairwell was recently lost to a disgraceful and heinous act of destruction. See The Funding Cases, 77 U.Va 1 (2024) (“Under cover of summer break, the administration laid waste to the elegant and stately passage at the front of Slaughter Hall. In its place is nothing but a Stalinesque wall.”). This Court is committed to vindicating its destruction.
The defendant staircase argues that no reasonable juror would find the Tiny Staircase too narrow. In doing so, Defendant attempts to fit a factual argument into a motion contending legal insufficiency. Such legal sloppiness is only tolerated by this Court when we already agree with the movant. Plaintiffs allege that the doorway is “roughly three feet across.” Pls.’ Aff. 1, para. 5. The average shoulder width of an adult ranges from fourteen to seventeen inches. While two adult individuals thus could fit through the three-foot wide doorway, there is naturally a need for some degree of personal space. The appropriate degree of personal space is a classic reasonableness question that is best reserved for a jury. Accordingly, we believe that the Tiny Staircase’s ability to accommodate Law School traffic is a question best resolved by the jury.
II
We now move to the Tiny Staircase’s argument that the existence of alternative stairwells prevents Plaintiffs from bringing this claim. Tiny Staircase misunderstands Plaintiffs’ argument and this Court’s precedent. Plaintiffs’ theory of harm includes an allegation that the Tiny Staircase slows their travel to and from classes, thus resulting in tardiness. In many instances, alternative stairwells will be an inadequate remedy for this injury due to their location at the far end of Slaughter Hall. The Tiny Staircase is the only access point in the middle of Slaughter Hall.
Regardless, Defendant is foolish to think we would dismiss this case on remedy exhaustion grounds. We balk at such procedural nonsense. We would much rather get to the substance of the case. See PRCP 17(a) (“All procedure and no substance makes the Court write dull opinions.”).
III
Lastly, the Tiny Staircase argues that Plaintiffs have misconstrued the false imprisonment tort. They note that a claim of false imprisonment is made only if the claimant’s “confinement within the boundaries fixed by the actor [is] complete.” Restatement 2d of Torts § 35. Here, Plaintiffs have only argued that they were slowed by the boundaries fixed by the Defendant. Plaintiffs were thus never confined, as a reasonable means of escape was always available to them.
While Tiny Staircase is perhaps correct that the Restatement does not support Plaintiffs’ legal theory, this Court has never let doctrine stand in the way of a good time. We believe that 2Ls and 3Ls, who are very busy golfing and planning how to spend their summer money, may adequately state a claim for false imprisonment if they are merely delayed by a defendant, rather than completely confined. We have no qualms about the potential for this holding to result in a slew of litigation about undue delays. Sounds really petty. We’re into that.
In sum, we find the Tiny Staircase’s arguments unavailing. Accordingly, we shall DENY their motion to dismiss. In the meantime, we encourage Plaintiffs to cook up some arguments that will allow us to order the administration to reinstate the old stairs. Long live Slaughter Hall.
It is so ordered.
Coleman, J., dissenting.
I dissent for two independent reasons. First, 2Ls and 3Ls lack standing based on the pleaded injury. Second, the Tiny Staircase offers some benefits, which I think amount to an affirmative defense to wrongful imprisonment.
With respect to standing, the majority asserts that the plaintiffs are harmed because they are late to class. That is no cognizable injury for upperclassmen! 1L is done for these people. The time for relaxation has arrived. To think that they should be concerned with arriving to class on time is ridiculous. The plaintiffs did also brief on third-party standing through 1Ls, but I find their arguments unconvincing. First, 1Ls rarely have classes in Slaughter. And second, they are free to litigate cases themselves. While they would almost certainly lose, that is not a sufficient bar to the assertion of their rights such that they would need surrogate plaintiffs.
And I would have used our common law powers to create a new affirmative defense for false imprisonment within our jurisdiction: offsetting benefits. It is no secret that this Court is rather blasé when ruling in tort. See Ex parte Undergrad, 77 U.Va. 4 (2024) (“If there is an undergraduate studying in our library, any law student, even a 1L, may imprison him within the Law School . . . .”). So, the concept of an affirmative defense to false imprisonment is nothing too offensive. And the benefits of Tiny Staircase are clear: People have to take things slowly and catch up with their fellow law students while waiting to access the stairs after class. Those little moments are what makes UVA special.
Finally, I would like to devote some space to a public attack on this Court’s Chief Justice (something I expect to see in the coming SCOTUS terms). This entire opinion is based on an idea that I already had and already wrote on. See In re Staircase. Not only is this joke theft, but it is redundant within the Law Weekly’s 77th edition. This malicious yet incompetent incident is perfectly consistent with the Chief Justice’s tenure.
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tya2us@virgina.edu
jxu6ad@virginia.edu
[1] Plaintiffs did not admit 1Ls to the class because, they explain, they were concerned that the inclusion of 1Ls could lead to an adverse ruling. See Liberals Who Are Bad at Using Canva v. Federalist Society at UVA Law, 76 U.Va 4 (2023) (“1Ls always lose.”). We applaud their wise decision.
[2] Attorneys’ for the Tiny Staircase strenuously objected to us referring to their client as “Tiny Staircase” and asked that we instead use “Mx. Slaughter Stairwell.” Defendant’s request is (obviously) denied. See PRCP 1 (“We do what we want.”); PRCP 3 (“The funniest outcome must necessarily prevail”).