Utah Federal Judge: Tennis Coach Dodges Negligence Claims After Choking Student

• A federal judge dismissed negligence claims against Utah tennis coach Lani Wilcox, ruling she was immune under state law because her actions were within the scope of employment.
• The ruling stems from an August 2022 incident where Wilcox put student Genevieve Olson in a chokehold after Olson slapped her.
• Civil rights claims against Wilcox and the Park City School District were also dismissed, though Olson can amend them.
• Claims of battery, assault, and intentional infliction of emotional distress against Wilcox remain active.
• Wilcox also faces state criminal charges for aggravated child abuse and interfering with a communication device, which were reinstated by the Utah Supreme Court.

The Utah tennis coach dodged negligence claims over the choking incident, as the judge concluded her actions, even if excessive, did not fall outside the bounds of her assigned duties.

A federal judge recently ruled that a Utah high school tennis coach, Lani Wilcox, is immune from negligence claims brought by a former student athlete, Genevieve Olson, whom Wilcox placed in a chokehold in 2022. U.S. District Judge Dale Kimball, a Bill Clinton appointee, issued the decision on Monday, dismissing Olson's claims of negligence and negligent infliction of emotional distress against Wilcox with prejudice. The ruling found that Wilcox was acting within the scope of her employment during the incident, thereby granting her protection under the Utah Government Immunity Act.

The altercation unfolded in August 2022 after Olson, then a minor, was informed she would be moved from the varsity doubles team to singles junior varsity. According to Olson's complaint, she went to the restroom to compose herself, but upon her return, Coach Wilcox allegedly berated her, threatened to remove her from the team, and advanced aggressively. Olson claims she feared for her safety and responded by slapping Wilcox. In turn, Wilcox reportedly put Olson in a chokehold, which Olson states restricted her breathing, caused physical pain, and emotional distress, and also confiscated her cell phone.

Judge Kimball acknowledged the severity of the coach's actions, noting that Wilcox "may have overzealously restrained a player who slapped her." However, he concluded that such conduct, even if excessive, did not fall outside the bounds of her assigned duties as a coach, which included teaching tennis and supervising students. Olson had sued Wilcox in her individual capacity in 2025, but the judge's interpretation of the state's immunity law proved decisive in this aspect of the case.

The core of Judge Kimball's decision rested on the Utah Government Immunity Act, which shields government employees from certain lawsuits when their actions are performed within the scope of their employment. Kimball emphasized that regardless of how Olson framed her arguments, the alleged injuries stemmed from or were connected to the physical conduct, which he deemed to be within Wilcox's professional capacity. This legal interpretation allowed the Utah tennis coach to dodge negligence claims over the choking incident.

Beyond the negligence claims, Judge Kimball also dismissed civil rights claims filed against both Wilcox and the Park City School District. However, unlike the negligence claims, Olson was granted the opportunity to amend these civil rights allegations. Kimball found Olson's initial civil rights complaint to be overly broad, stating it made "sweeping claims alleging neglect, abuse and inhumane treatment along with a list of seven (now pared down to three) constitutional amendments allegedly violated," without adequately specifying which facts supported each claim.

Furthermore, the judge did not find sufficient evidence to support Olson's assertion that the school district maintained a pattern or policy of ignoring or downplaying misconduct. Kimball clarified that to demonstrate such a custom, policy, or practice, Olson would need to show a pattern of physical restraint used by coaches and teachers in a manner that was explicitly unlawful, not merely a pattern of physical restraint itself. He noted that Utah law, at the time of the incident, permitted school employees to use reasonable physical restraint to protect students or others.

Despite the dismissal of the negligence and civil rights claims, Coach Lani Wilcox still faces significant legal challenges. Olson's claims of battery, assault, and intentional infliction of emotional distress against Wilcox remain active and were not affected by the federal judge's recent ruling. These claims will proceed.

In addition to the ongoing civil litigation, Wilcox is also confronting state criminal charges in Utah’s Third Judicial District. She is accused of aggravated child abuse and interfering with the use of a communication device. These criminal charges have a complex history; they were initially dismissed in 2023, but the Utah Supreme Court reversed that dismissal and remanded the case last year. The state's highest court determined that Wilcox's belief that Olson posed an imminent threat to others was not objectively reasonable, thereby allowing the criminal proceedings to continue. Wilcox is partially represented in these matters by the Utah Attorney General’s Office and the Salt Lake City Attorney’s Office.

Source: Original reporting via Courthouse News