I haven't seen any of the pleadings in the case, so I have no idea what's going on in the litigation. It has been my position since the time it happened, though, that because the University actively prohibited those students, staff, and faculty who might have otherwise been in lawful possession of the means of self defense, the failure to actively protect each of the persons shot was negligence. The University assumed the highest possible duty to the students, in particular, and negligently breached that duty, and that breach of duty was the proximate and efficient cause of the student's deaths and injuries. Moreover, since the decision boiled down ultimately to a question of money (the cost of actively protecting each classroom), that negligence was willful, intentional, and malicious. The University made a conscious decision not to spend the money on armed guards sufficient to keep the students safe, and that decision cost those students their lives. That's a basis for punitive damages.
In advancing that argument, some attorneys have argued that it would be necessary to show that there was at least one person who would have actually been armed that day. Assuming they're right, I'm guessing that wouldn't be too hard to do at Va. Tech.
By the way, my number 3 kid is a graduate of their business school, so they keep sending me requests for money. I tell them not one cent for them as long as they're actively putting the lives of students in danger.