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In 2013, in Morrow v. Balaski, the U.S. Court of Appeals for the Third Circuit held that a school did not have a constitutional duty to protect two students from being bullied. The court reasoned that no special relationship existed between the school and the students and the school’s actions did not create the harm that was inflicted on the students. This Comment argues that courts should find a special relationship between a school and its students when a school’s behavioral restrictions render the students dependent on the school for their safety.