Background
Sage Bainter was a high school student enrolled in a welding class at the Madison County Area Technology Center (ATC), a career and technical education school operated by the Kentucky Department of Education in Richmond, Kentucky. His instructor, Tim Pinson, directed Bainter and four other male students to move a heavy scrap-metal plate from an outdoor scrapyard into the building’s welding lab. Rather than supervising the task, Pinson was in a separate classroom with his feet on his desk, talking on the phone. Students whom Pinson had placed in charge of the class pressured and taunted Bainter and the others into carrying the plate. The students lost control of it, and it fell to the floor, crushing Bainter’s hand.
Bainter filed a personal injury action in November 2022 in Madison Circuit Court, suing Pinson both in his official capacity and in his individual capacity, alleging negligent failure to supervise. After discovery, Pinson moved for summary judgment, arguing that the claim against him in his official capacity was barred by governmental immunity and that the claim against him individually was barred by qualified official immunity because his supervisory decisions were discretionary rather than ministerial and were made in good faith. He also argued that his conduct was not the legal cause of Bainter’s injury.
The Madison Circuit Court denied summary judgment on March 3, 2025, holding that a teacher’s duty to supervise students is ministerial under Kentucky law, that no heightened discretion was required merely because the setting involved a welding workshop and scrapyard, and that taking a phone call did not elevate Pinson’s choices to discretionary acts. The court’s ruling on causation was not challenged on appeal; only the immunity question was before the Court of Appeals.
The Court’s Holding
The Kentucky Court of Appeals affirmed the denial of summary judgment, holding that Pinson’s duty to supervise his students was ministerial in nature and therefore not shielded by qualified official immunity. Applying Yanero v. Davis, 65 S.W.3d 510 (Ky. 2001), the court reiterated that qualified official immunity protects only discretionary acts — good-faith judgment calls made in a legally uncertain environment — and does not extend to the negligent performance of a ministerial duty, which is one that is absolute, certain, and imperative.
The court found that Pinson was bound by explicit, repeated directives requiring him to supervise students at all times, never leave them unattended, and ensure their safety in the lab and workshop. Because he was required to implement policy set by others — not to craft it — his obligation was ministerial. The court rejected Pinson’s argument that the hazardous nature of the welding environment and scrapyard converted his supervisory role into a discretionary function, relying on Marson v. Thomason, 438 S.W.3d 292 (Ky. 2014), for the principle that a ministerial duty is not transformed into a discretionary one merely because some modicum of judgment is involved in how it is carried out.
The court was careful to note that its ruling does not establish Pinson’s liability or foreclose other defenses available to him; it holds only that qualified official immunity is unavailable as a matter of law on these facts. All three judges concurred.
Key Takeaways
- Under Kentucky law, a public-school teacher’s duty to supervise students is ministerial — not discretionary — because it requires enforcement of known rules imposed by statute and school policy, and qualified official immunity therefore does not apply when that duty is negligently performed or abandoned.
- The hazardous or specialized nature of a classroom environment (here, a vocational welding lab and outdoor scrapyard) does not by itself elevate supervision into a discretionary function; the relevant question is whether the teacher was implementing policy set by others or exercising independent policymaking authority.
- That a ministerial task requires some judgment about the means or method of performance does not convert it into a discretionary act — a teacher who must use common sense to avoid negligence is still performing a ministerial duty.
- A teacher’s explicit, written notice of mandatory supervision requirements (e.g., “students are always to be supervised — period”) weighs heavily against any claim that supervisory choices were discretionary good-faith judgment calls.
Why It Matters
This decision reinforces and applies Kentucky’s well-settled rule that teacher supervision is a ministerial duty, but does so in a context — career and technical education involving industrial equipment and outdoor work areas — where a defendant might plausibly argue that heightened professional judgment is required. By rejecting that argument, the court signals that vocational and CTE instructors in Kentucky are not insulated from personal liability by qualified immunity simply because their classrooms are more dangerous or operationally complex than a standard academic setting.
For school districts and their insurers, the opinion underscores the practical importance of clear, written supervision policies and adequate staffing: explicit directives requiring constant student oversight will be treated as creating absolute ministerial obligations for individual teachers, not as mere guidance subject to professional discretion. Plaintiffs’ attorneys pursuing negligent-supervision claims against Kentucky public-school employees in individual-capacity suits will find this decision a useful roadblock to early immunity dismissals.