Patton v. Bickford, 529 S.W.3d 717

Eighth-grader Stephen Patton committed suicide; his estate sued ACMS teachers and administrators alleging they knew or should have known of persistent school bullying and failed to prevent or report it.
Trial court granted summary judgment for Teachers and Administrators on qualified official immunity and as to suicide being a superseding intervening cause; Court of Appeals affirmed based on intervening cause but held defendants lacked immunity (teachers/administrators deemed ministerial).
Kentucky Supreme Court reviewed: held Administrators entitled to qualified official immunity for policy-making; Teachers not immune because their duty to supervise/report was ministerial under school policy.
The Court recognized that bullying-induced suicide can, in some circumstances, support a wrongful-death claim (suicide not inherently a superseding intervening cause).
Nonetheless, the Court affirmed summary judgment for the Teachers on a different ground: Estate failed to present sufficient non-speculative evidence linking bullying (or teacher breach) as the but-for or proximate cause of Stephen’s suicide.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Qualified official immunity for administrators	Administrators negligently promulgated/implemented policies; should be liable	Policy formation and related acts are discretionary and immune	Administrators immune: policy formulation/assessment discretionary; summary judgment for administrators affirmed
Qualified official immunity for teachers	Teachers negligently supervised, failed to stop/report bullying; no immunity	Teachers performed discretionary judgments; claim barred by immunity	Teachers not immune: duty to supervise and report is ministerial under policy; can be sued
Suicide as superseding intervening cause	Suicide severs liability for school actors	Suicide is generally unforeseeable and superseding	Suicide is not categorically superseding where bullying foreseeably causes suicide; wrongful-death claim can lie in appropriate circumstances
Causation (but-for/proximate) sufficient to survive summary judgment	Evidence (student affidavits, email, experts) shows persistent bullying and teacher knowledge causing suicide	Evidence is speculative; other causes (migraines, mental disorder) more plausible	Estate failed to produce non-speculative evidence linking bullying/teacher breach as but-for or proximate cause; summary judgment for teachers affirmed

Yanero v. Danis, 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) (administrator discretion; teacher supervisory duties often ministerial)
Knott County Bd. of Educ. v. Patton, 415 S.W.3d 51 (Ky. 2013) (distinguishes statutory-mandated duties from policy choices)
Williams v. Kentucky Dept. of Education, 113 S.W.3d 145 (Ky. 2003) (promulgation vs enforcement distinction)
Steelvest, Inc. v. Scansteel Service Ctr., Inc., 807 S.W.2d 476 (Ky. 1991) (summary judgment standard; genuine issue of material fact)
Shelton v. Kentucky Easter Seals Society, Inc., 413 S.W.3d 901 (Ky. 2013) (summary judgment burdens and review)
House v. Kellerman, 519 S.W.2d 380 (Ky. 1975) (discussion of causation and intervening causes)
Pathways, Inc. v. Hammons, 113 S.W.3d 85 (Ky. 2003) (elements of negligence and causation analysis)
Craft v. Rice, 671 S.W.2d 247 (Ky. 1984) (recognition of recovery for outrageous conduct causing severe emotional distress)
Blackstone Mining Co. v. Travelers Ins. Co., 351 S.W.3d 193 (Ky. 2010) (summary judgment appropriate where nonmoving party relies on speculation)