Patton v. BickfordAnnotate this Case
Stephen Patton, an eighth-grader at Allen Central Middle School, committed suicide allegedly because he was bullied at school. Patton’s estate filed suit against various teachers and administrators alleging that the administrators failed to implement sound policies and that the teachers failed to know Patton was being bullied and mistreated under their watch. The trial court granted summary judgment in favor of the teachers and administrators, concluding (1) these defendants were entitled to qualified official immunity from suit, and (2) Patton’s suicide was an intervening cause interrupting potential liability by the teachers and administrators. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the trial court erred when it ruled that the teachers were entitled to the protection of qualified official immunity from this suit but did not err in ruling that the administrators were protected by qualified immunity; and (2) the trial court did not err in granting summary judgment to the teachers where the Estate presented no credible evidence that Patton was bullied because the teachers were negligent either in their duty to handle bullying reports or to appropriately supervise their pupils.