A parent may also be held responsible for failure to exercise reasonable control over the child when the parent knows, or should know, that injury to another is a probable consequence. See, e.g., Cashman v. Reider's Stop-N-Shop Supermarket (1986), 29 Ohio App.3d 142, 29 OBR 158, 504 N.E.2d 487; Landis v. Condon (1952), 95 Ohio App. 28, 52 O.O. 371, 116 N.E.2d 602; Parsons v. Smithey (Ariz. 1973), 504 P.2d 1272; Gissen v. Goodwill (Fla. 1955), 80 So.2d 701; see, also, 2 Restatement of the Law 2d, Torts (1965), Section 316. Finally, when parents know of the child's wrongdoing and consent to it, direct it or sanction it, they may be held liable.
350 S.W.2d 524 The cases of Landis v. Condon, 95 Ohio App. 28, 116 N.E.2d 602 (1952) and Caldwell v. Zaher, 344 Mass. 590, 183 N.E.2d 706 (1962) are recent cases where parents have been held liable for their children's willful assaults, when the parents knew of the children's propensities to assault others, but failed to take any steps to correct or restrain the children. 67 C.J.S. Parent and Child sec. 68 has this to say:
See Sousa v. Irome, 219 Mass. 273, 276; Gudziewski v. Stemplesky, 263 Mass. 103, 105-106; Sojka v. Dlugosz, 293 Mass. 419, 423; Norlin v. Connolly, 336 Mass. 553, 554. We believe that the principle is equally applicable where the parents' negligence is, as here, based on allegations that they knew of their child's propensity toward assaulting other children and "did nothing" (emphasis supplied) to halt it. Bieker v. Owens, 234 Ark. 97. Gissen v. Goodwill, 80 So.2d 701, 703-705 (Fla.). Steinberg v. Cauchois, 249 App. Div. (N.Y.) 518, 519. Agnesini v. Olsen, 277 App. Div. (N.Y.) 1006. Zuckerberg v. Munzer, 277 App. Div. (N.Y.) 1061. Landis v. Condon, 95 Ohio App. 28, 29-30. Condel v. Savo, 350 Pa. 350, 352-355.
{ΒΆ 26} In Ohio, parental knowledge of a child's "vicious propensities" is an essential element in establishing negligent supervision. Landis v. Condon , 95 Ohio App. 28, 29β30, 116 N.E.2d 602 (2d Dist.1952). " βTo establish foreseeability of the act or injury [pursuant to negligent supervision], plaintiff must prove that specific instances of prior conduct were sufficient to put a reasonable person on notice that the act complained of was likely to occur.
{ΒΆ 20} In order to establish negligent supervision, parental knowledge of a child's "vicious propensities" is an essential element. Shupe, supra, at ΒΆ 16, citing Landis v. Condon (1952), 95 Ohio App. 28, 29-30. "`To establish foreseeability of the act or injury (pursuant to negligent supervision), plaintiff must prove that specific instances of prior conduct were sufficient to put a reasonable person on notice that the act complained of was likely to occur.'"
{ΒΆ 16} In Ohio, parental knowledge of a child's "vicious propensities" is an essential element in establishing negligent supervision. Landis v. Condon (1952), 95 Ohio App. 28, 29-30, 116 N.E.2d 602. "`To establish foreseeability of the act or injury [pursuant to negligent supervision], plaintiff must prove that specific instances of prior conduct were sufficient to put a reasonable person on notice that the act complained of was likely to occur.'" (Alteration in original.)
In Ohio, parental knowledge of a child's "vicious propensities" is an essential element in establishing negligent supervision. Landis v. Condon (1952), 95 Ohio App. 28, 29-30. "`To establish foreseeability of the act or injury [pursuant to negligent supervision], plaintiff must prove that specific instances of prior conduct were sufficient to put a reasonable person on notice that the act complained of was likely to occur.'"
s); Caldwell v. Zaher, 344 Mass. 590, 183 N.E.2d 706 (1962) (child with habit of assaulting, accosting, tormenting and molesting young children assaulted, accosted, tormented and molested young child); Gudziewski v. Stemplesky, 263 Mass. 103, 160 N.E. 334 (1928) (child who had used an air gun, not a dangerous instrumentality, indiscriminately and mischievously on three occasions by placing children in a line and pointing the air gun at them from a distance of ten or eleven feet, shooting at clothes hanging in the yard to dry and shooting at a shanty and birds, used the air gun to shoot another child in the eye); Lane v. Chatham, 251 N.C. 400, 111 S.E.2d 598 (1959) (child who had three times misused an air rifle, not a dangerous instrumentality, by shooting person in hip, shooting another person with match stems in arms and legs and chasing another person a couple of times while carrying air rifle without firing it, pointed air rifle directly at another person and shot him in the eye); Landis v. Condon, 95 Ohio App. 28, 116 N.E.2d 602 (1952) (child with vicious propensities and disposition jumped upon another child's back and threw the child to the floor); Sawyer v. Kelly, 194 Okla. 516, 153 P.2d 97 (1944) (child who was permitted to ride horse with only a halter to control the animal was riding the horse when it ran into an automobile); Condel v. Savo, 350 Pa. 350, 39 A.2d 51 (1944) (child with habit of mauling, pummelling, assaulting and mistreating smaller children threw another child down a steep and precipitous embankment); Bocock v. Rose, 213 Tenn. 195, 373 S.W.2d 441 (1963) (children who had a propensity to assault others assaulted and battered plaintiff); Eldredge v. Kamp Kachess Youth Servs., Inc., 90 Wn.2d 402, 583 P.2d 626 (1978) (children who had escaped from a group child care facility, whose legal standard of care was that of a parent, had stolen and abandoned an automobile and had committed a burglary, were apprehended and reassigned to the same facility, escaped again, stole an automobile and wrecked the