Patton v. Bickford

The estate of Stephen Patton, an eighth-grader who committed suicide, filed suit against various teachers and administrators, claiming that Defendants should have known of the bullying Stephen was subjected to at school and taken steps to prevent it. The circuit court granted summary judgment in favor of Defendants, ruling (1) Defendants were protected by qualified immunity, and (2) Stephen’s suicide was a superseding intervening cause interrupting any potential liability of Defendants. The court of appeals upheld the summary judgment solely on the intervening cause issue and ruled that Defendants were not entitled to qualified official immunity. The Supreme Court affirmed the court of appeals’ opinion to uphold summary judgment but for different reasons, holding (1) while the Administrators were protected by qualified immunity, the Teachers were not immune from suit on the basis of qualified official immunity; (2) bullying and tormenting behavior, if shown to be the proximate cause of a suicide, may form the basis for a wrongful death claim by the decedent’s estate; but (3) under the facts of this case, the Estate failed to make a prima facie showing that the Teachers’ conduct of failing to prevent the bullying of Stephen was the “but-for” cause or the proximate cause of Stephen’s suicide. View "Patton v. Bickford" on Justia Law