A story in the Houston Chronicle (AP) discusses the possibility:
Five years before the massacre at Virginia Tech, a deeply disturbed student went on a murderous rampage at the Appalachian School of Law, killing three and wounding three others.
Some victims and family members sued the law school and eventually settled for $1 million. Similar lawsuits are virtually certain after the Virginia Tech shootings, but legal experts say it could be very difficult to win damages.
And another one by at FindLaw by Anthony Sebok:
But once an investigation is complete, what will it tell us? If it turns out that there was negligence, or worse, on the part of the university or others, can the wounded victims or the families of the deceased victims of the attack sue Virginia Tech for damages?
The answer is not very reassuring for the families or the surviving victims, and it raises important questions about whether we want to insulate the state from accountability in court for its mistakes.
One thing I can say with some level of certainty, that even if such suits are successful, they will be cold comfort for those in mourning.