Floyd Lawrence Patton as Administrator of the Estate of Stephen Lawrence Patton v. Davida Bickford, 2013 SC 000560

Stephen Patton, an eighth grader at Allen Central Middle School, committed suicide; his mother (later successor) sued teachers and administrators alleging they knew or should have known Stephen was persistently bullied and failed to prevent or report it.
The Estate alleged negligence for failure to supervise (teachers) and for inadequate policy creation/implementation (administrators).
Trial court granted summary judgment for both teachers and administrators based on qualified official immunity and that suicide was a superseding intervening cause; Court of Appeals affirmed on the intervening-cause ground but found the defendants immune; Supreme Court modified holdings.
The Supreme Court held administrators (policy makers) are entitled to qualified official immunity for discretionary policymaking but teachers (policy enforcers) perform ministerial duties (duty to report/supervise) and are not immune.
The Court ruled bullying-induced suicide can, in principle, support a wrongful-death claim (suicide is not per se a superseding intervening cause), but affirmed summary judgment for the teachers because the Estate failed to present non-speculative evidence establishing causation linking alleged bullying to Stephen’s suicide.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Qualified official immunity for administrators	Administrators negligently adopted/implemented policies; thus liable	Policy formation and oversight are discretionary and immune	Administrators entitled to qualified immunity for policy formulation/oversight (discretionary), so summary judgment for administrators affirmed
Qualified official immunity for teachers	Teachers negligently supervised, failed to stop/report bullying	Teachers are also entitled to immunity	Teachers are not immune: supervision/reporting duties are ministerial; they can be sued
Suicide as superseding intervening cause	Stephen's suicide cuts off liability for alleged negligence	Suicide is an independent, unforeseeable intervening act absolving defendants	Suicide is not categorically a superseding intervening cause when the defendant’s conduct foreseeably induces suicide (bullying can be proximate cause)
Causation (but-for and proximate) linking bullying to suicide	Student affidavits and policy violations show bullying and knowledge by teachers; causation established	Evidence insufficient to non-speculatively link bullying to suicide (medical history, no note, experts limited)	Estate failed to produce sufficient non-speculative evidence of causation; summary judgment for teachers proper on causation grounds

Yanero v. Davis, 65 S.W.3d 510 (Ky. 2001) (defines qualified official immunity and discretionary vs. ministerial duties)
Marson v. Thomason, 438 S.W.3d 292 (Ky. 2014) (teachers' general supervision is ministerial; administrators' policymaking is discretionary)
Steelvest, Inc. v. Scansteel Service Center, Inc., 807 S.W.2d 476 (Ky. 1991) (summary judgment standard; nonmoving party must present affirmative evidence of genuine fact issue)
Knott County Board of Education v. Patton, 415 S.W.3d 51 (Ky. 2013) (distinguishes ministerial statutory duties from discretionary policy choices)
Craft v. Rice, 671 S.W.2d 247 (Ky. 1984) (adopts Restatement § 46 for outrageous conduct causing severe emotional distress)
House v. Kellerman, 519 S.W.2d 380 (Ky. 1974) (discusses proximate cause and superseding intervening causes)
Pathways, Inc. v. Hammons, 113 S.W.3d 85 (Ky. 2003) (elements of negligence and which issues are questions of law vs. fact)