BARNETT v. CALDWELL, 302 Ga. 845

Antoine Williams, a high-school student, collapsed and later died after horseplay in his seventh-period class when his teacher, Phyllis Caldwell, left the classroom and another student landed on him. Caldwell returned after about 30 minutes and called 911.
Caldwell had asked the neighboring teacher, Gibril Kanu, to “listen out” for her class; Kanu could not see into Caldwell’s classroom from his seat. A hall monitor (a retired assistant principal) was nearby but was not asked to supervise.
The school faculty handbook (Section 6.5) stated classroom teachers are solely responsible for supervision and that students are never to be left in the classroom unsupervised by an APS certificated employee; it did not define “supervise” or “unsupervised.”
Caldwell initially lied about being present during the incident; later investigations showed she had left the classroom. She offered multiple explanations for leaving (phone, copies, restroom).
Antoine’s parents sued Caldwell individually for negligent supervision. The trial court granted summary judgment for Caldwell on official-immunity grounds; the Court of Appeals affirmed. The Georgia Supreme Court granted certiorari.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Caldwell’s absence from the classroom violated a ministerial duty (no official immunity) or involved discretionary judgment (entitled to official immunity)	Barnett: The handbook’s prohibition on leaving students “unsupervised” created a ministerial duty to remain present; Caldwell violated a clear policy and is individually liable.	Caldwell: Supervision decisions require personal judgment (when to leave, whom to ask, whether monitoring by others suffices); thus actions were discretionary and protected by official immunity.	The Court held the supervision policy was not sufficiently definite to create a ministerial duty; Caldwell’s choices required discretion, so she is entitled to official immunity (no liability absent malice).

Gilbert v. Richardson, 264 Ga. 744 (Georgia 1994) (origins and purpose of official immunity)
McDowell v. Smith, 285 Ga. 592 (Georgia 2009) (distinguishing ministerial versus discretionary functions)
Murphy v. Bajjani, 282 Ga. 197 (Georgia 2007) (definition of ministerial act)
Roper v. Greenway, 294 Ga. 112 (Georgia 2013) (policy or directive must be so specific to convert discretionary act into ministerial)
Eshleman v. Key, 297 Ga. 364 (Georgia 2015) (duty must be particularized and certain to be ministerial)
Grammens v. Dollar, 287 Ga. 618 (Georgia 2010) (policy lacking definition of key term leaves discretion to employee)
Barnett v. Atlanta Independent School System, 339 Ga. App. 533 (Ga. App. 2016) (Court of Appeals opinion below affirmed by Supreme Court)