Off-Campus Liability and Churches

Off-campus liability is an ongoing question for churches and church leaders to address in light of these key cases.

Church events often happen beyond the building’s walls. That’s why understanding legal risks tied to off-campus activities is critical.

Courts have weighed in on this issue in both church-related and non-religious charity cases. These examples offer key insights for ministry leaders.


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Why This Matters

Church leaders should:

  • Review the facts of each legal case
  • Understand court decisions
  • Identify practical takeaways and risk factors

Doing so helps churches evaluate their potential liability for off-site activities.


Case Study 1: Church Picnic ATV Accident

A Sunday School teacher organized a picnic on a member’s property. While the pastor attended, he did not help plan the event.

Key facts:

  • Invitations were shared during Sunday School.
  • Church members brought food and recreational equipment, including rifles and an ATV.
  • A 15-year-old drove the ATV on a public road, injuring a passenger.

The injured party’s parents sued the driver’s parents and the church. The court ruled:

  • The church’s insurance policy did not cover the incident.
  • Policy language clearly limited coverage to activities performed on behalf of or at the direction of the church.
  • The church had no role in authorizing the ATV’s use.

Key takeaway: A church may be liable only when an activity is directed, requested, or carried out for its benefit.

Case citation: ASI Insurance Company, 2022 WL 2760479 (N.D. Fla. 2022)


Case Study 2: Halloween Hayride Injury

A woman was seriously injured while preventing a child from falling off a church-sponsored hayride.

The appellate court reversed a trial court dismissal based on:

  • Overloading: The church allegedly decided ride precautions, lighting, and passenger limits.
  • Negligent Supervision: Poor lighting and a lack of control over rowdy children on the trailer.

The court found the church owed a duty of care to children it was supervising.

Key takeaway: Inadequate supervision, overloading, and poor planning can create church liability.

Case citation: Clontz v. St. Mark’s Evangelical Lutheran Church, 578 S.E.2d 654 (N.C. App. 2003)


Case Study 3: Deadly After-School Party

A church-operated school faced a lawsuit after two students died following an off-campus, unsanctioned party where alcohol was consumed.

Verdict Breakdown

  • The school and its principal settled for $1.1 million.
  • A jury assigned 25% fault to the school and awarded $55+ million in damages.
  • The appellate court ruled the party was neither school-sponsored nor school-related.

Key takeaways:

  • Liability requires more than just awareness of an off-campus event.
  • Courts distinguish between sponsored and related activities.

Case citation: Archbishop Coleman F. Carroll High School, Inc. v. Maynoldi, 30 So.3d 533 (Fla. App. 2010)


Case Study 4: Youth Soccer Club Carpool Crash

A 16-year-old, at a coach’s direction, transported teammates to practice and caused a major crash.

Court Decision

  • Though 83% of fault was assigned to the driver, the soccer club was ordered to pay the full verdict due to the coach’s control over logistics.
  • The court confirmed the legal principle of respondeat superior—an organization may be liable for the actions of volunteers acting under its authority.

Key takeaway: Direction and control over a volunteer’s actions can trigger liability—even without formal employment.

Case citation: Bartell ex rel. Hoesel v. Mesa Soccer Club, 2010 WL 502993 (Ariz. App. 2010)


Additional Cases Highlighting Liability Factors

Baseball Game Carpool Tragedy

A 16-year-old volunteer driver caused a fatal crash. The court said a jury must decide if the sponsoring organization (the American Legion) was liable.

Case: Daniels v. Reel, 515 S.E.2d 22 (N.C. App. 1999)


A church volunteer struck a motorcyclist while delivering cookies. The court found the church may be liable due to its control over the volunteer’s actions.

Case: Trinity Lutheran Church, Inc. v. Miller, 451 N.E.2d 1099 (Ind. App. 1983)


School Officials Aware of Underage Drinking

A student died in a crash after an unsanctioned party. Although school officials were aware of the drinking, the court ruled the school had no duty since the party was not officially sanctioned.

Case: Rhea v. Grandview School District, 694 P.2d 666 (1985)


Hazing at Club Meeting

A student was injured during a hazing incident at a school-sponsored, off-campus club meeting. The court found the school liable.

Case: Rupp v. Bryant, 417 So.2d 658 (Fla. 1982)


Unauthorized Teacher Excursion

A college was not liable when a teacher led a student outing after classes had ended. The outing was not authorized or affiliated with the school.

Case: Fernandez v. Florida National College, Inc., 925 So.2d 1096 (Fla. App. 2006)


Final Takeaways for Church Leaders

Liability for off-campus activities isn’t automatic—but it’s possible.

When Is a Church More Likely to Be Liable?

  • The activity is directed, requested, or benefits the church.
  • The church officially endorses, promotes, or provides resources for the event.
  • Staff or leaders attend in an official capacity.

Questions to Ask Before Off-Site Events

  1. Was the event planned by a recognized church committee or group?
  2. Did planners seek permission or resources from the church?
  3. Has the church helped coordinate logistics?
  4. Was the event promoted in church channels?
  5. Will staff attend as official representatives?

If the answer to any of these is “yes,” the event may be viewed as church-related—and liability increases.


Risk Mitigation Strategies

To reduce risks during off-campus events:

  • Assign trained staff or volunteers.
  • Ensure adequate lighting and safety precautions.
  • Limit crowd size or participation.
  • Screen and select drivers carefully.
  • Hire professionals for high-risk activities.

Consult with legal counsel and your insurance provider before the event.


Consider a Non-Sanctioned Event Policy

A clear policy stating the church will not be liable for events it does not officially sanction may help demonstrate your position.

While not a complete legal shield, it may reduce exposure—especially when coupled with:

  • A formal event approval process
  • Guidelines for requesting sponsorship
  • Leadership training in liability awareness


Further Reading: This church was found not liable for injuries sustained by a teenager at an off-campus church event. Click here to find out the specifics.


Richard R. Hammar is an attorney, CPA and author specializing in legal and tax issues for churches and clergy.

This content is designed to provide accurate and authoritative information in regard to the subject matter covered. It is sold with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional service. If legal advice or other expert assistance is required, the services of a competent professional person should be sought. "From a Declaration of Principles jointly adopted by a Committee of the American Bar Association and a Committee of Publishers and Associations." Due to the nature of the U.S. legal system, laws and regulations constantly change. The editors encourage readers to carefully search the site for all content related to the topic of interest and consult qualified local counsel to verify the status of specific statutes, laws, regulations, and precedential court holdings.

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