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Fraternity Off The Hook for Post-Party Murder (PA)

October 9, 2019

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<p style="text-align: justify;">An Eastern District of Pennsylvania Court recently examined whether a fraternity could be held liable for the murder of a student that occurred after a fraternity party.</p>
<p style="text-align: justify;">The facts in <em><a href="">Hall v Millersville University</a> </em>are tragic. It was alleged that the decedent was in a tumultuous relationship with Greg Orrostieta. The decedent and Greg would often stay overnight together at Greg’s residence or in the decedent’s dorm room. The decedent was a student at Millersville but Greg was not. Ample testimony indicated that there was physical abuse in the relationship, and it was alleged that this physical abuse was known to the fraternity and Millersville.  More specifically, the night of the murder, the decedent and Greg went to a party at the fraternity. Multiple fraternity brothers saw a physical and verbal confrontation, which included Greg pushing the decedent against the wall. The fraternity brothers further testified that subsequent to this altercation, Greg and the decedent were dancing together. The fraternity brothers testified that, in context, “everything’s good” after the altercation, as the couple were dancing together again. Importantly, after the party, multiple fraternity brothers had a conversation with one of decedents’ friends, and that a confrontation was needed the next day with respect to Greg’s behavior.</p>
<p style="text-align: justify;">In the main, the Court granted summary judgment for all defendants, holding that murder was an unforeseeable, extraordinary act, and that none of the defendants' actions/omissions were the proximate cause of the decedent's death. The Court concluded that the fact pattern simply wasn’t sufficiently severe to place the fraternity or Millersville on notice of a potential murder that night. More specifically, the Court concluded that the fraternity simply could not know that “among the partygoers would be an individual capable of murdering his girlfriend.”</p>
<p style="text-align: justify;">This case serves as a reminder that summary judgment is still a useful tool in cases with extraordinarily sympathetic facts to the plaintiff.</p>
<p style="text-align: justify;">Thanks to Matthew Care for his contribution to this post.  Please contact <a href="">Georgia Coats</a> with any questions.</p>


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