The Illinois Supreme Court has affirmed tort immunity protections for Kankakee School District 111 and its employee in *Haase v. Kankakee School District 111*, reversing an appellate court decision that would have exposed the district to liability for a student's gym class injury.
Justice Cunningham delivered the unanimous opinion on November 20, 2025, with all seven justices concurring in the judgment. The court held that the school district and teacher Darren Wilbur Dayhoff were entitled to immunity under multiple sections of the Local Governmental and Governmental Employees Tort Immunity Act.
The case stems from a February 16, 2018 lawsuit filed by Kevin Haase, both individually and as parent of his son Riley Haase, a student at Kankakee School District 111. The complaint targeted both the district and Dayhoff, who served as a teacher in the district at the time of the incident.
The original circuit court in Kankakee County granted summary judgment to the defendants, concluding they were immune from liability under sections 2-109, 2-201, and 3-108 of the Tort Immunity Act. This comprehensive statutory framework provides broad protections for local governmental entities and their employees from tort liability in various circumstances.
Section 2-109 of the Tort Immunity Act provides immunity for injuries resulting from the condition of public property intended for recreational purposes. Section 2-201 grants immunity for injuries caused by the failure to provide police protection, while section 3-108 specifically addresses immunity for injuries occurring on school property during supervised activities.
However, the Illinois Appellate Court for the Third District reversed the trial court's decision in 2024, finding that the immunity protections did not apply to the specific circumstances of Riley's injury. The appellate court's ruling in *Haase v. Kankakee School District 111* would have allowed the tort lawsuit to proceed against both the district and the individual teacher.
The Supreme Court's reversal of the appellate decision restores the original summary judgment ruling and provides clarity on the breadth of governmental immunity protections available to school districts. The decision reinforces that educational institutions and their employees enjoy substantial protection from tort liability when operating within their official capacities.
The case highlights the ongoing tension between providing adequate remedies for injured students and protecting public educational institutions from potentially costly litigation. School districts across Illinois have closely watched this case, as it could impact how they approach risk management and safety protocols in physical education programs.
The Tort Immunity Act serves as a critical protection for local governments and school districts, which might otherwise face unlimited liability exposure for injuries occurring on their premises or during their activities. The statute recognizes that public entities provide essential services and should not be deterred from their missions by excessive litigation risks.
Riley Haase reached the age of majority during the pendency of the litigation, which began in 2018 and continued through multiple court proceedings over several years. By September 12, 2022, Riley was able to participate directly in the legal proceedings as an adult plaintiff alongside his father.
The Supreme Court's decision provides important guidance for future cases involving student injuries in educational settings. School districts can rely on this precedent when defending against similar claims, while plaintiffs' attorneys must carefully evaluate whether specific circumstances might fall outside the immunity protections.
The unanimous nature of the Supreme Court's decision suggests strong agreement among the justices regarding the proper interpretation of the Tort Immunity Act in the school context. This consensus strengthens the precedential value of the ruling and reduces uncertainty about how similar cases will be resolved in the future.
For Kankakee School District 111, the decision represents a complete victory after years of litigation. The district avoided potential damages and established favorable precedent for defending against future injury claims arising from school activities.
The case also demonstrates the multi-layered nature of governmental immunity law in Illinois, where different statutory sections can provide overlapping protections for public entities. The circuit court's original analysis of sections 2-109, 2-201, and 3-108 shows how comprehensive these protections can be when properly applied.
Moving forward, school districts should continue maintaining appropriate safety protocols while understanding that the law provides substantial protection for good-faith efforts to educate students. The decision reinforces that public education remains a governmental function deserving of tort immunity protections under Illinois law.