On December 8, 2008, the California Court of Appeal, Second District, published its decision in Jennifer C. v. Los Angeles Unified School District (2008) 168 Cal.App.4th 1320 holding that maintenance of a “hiding place” where a special needs child could be victimized made the foreseeability of an assault easier to prove. The court reversed a decision by the superior court to dismiss the case against the district resulting from such an assault, and sent it back for the case to proceed to trial., search terms:, Jennifer c. v. Los Angeles Unified School District, hiding place, special needs, sexual assault, victimized, Thompson v. Sacramento Unified School District,
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