Barnett v. Caldwell-Immunity for Teacher

High school student Antoine Williams tragically died after engaging in horseplay with another student while his teacher was out of their classroom. Antoine’s parents, appellants Jena Barnett and Marc Williams filed a complaint against Appellee Phyllis Caldwell, the teacher. They alleged that Caldwell was liable in her individual capacity for Antoine’s wrongful death because she had been negligent in supervising his classroom. The trial court granted Caldwell’s motion for summary judgment, concluding that she was entitled to official immunity because her acts were the product of discretionary decisions concerning the supervision of students. The Court of Appeals affirmed. After review, the Georgia Supreme Court concluded that student supervision was not unalterably discretionary in all respects, but here, because the school’s policy was not so definite as to render Caldwell’s actions ministerial, therefore, she was entitled to official immunity.

Source: Justia Law