In April 2026, the Supreme Court of Queensland delivered judgment in Frazer v State of Queensland [2026] QSC 82.
The case involved a teacher who alleged that she suffered psychological injury, including post-traumatic stress disorder, after an incident involving an aggrieved parent at a State high school.
This case is useful because it discusses workplace psychological injury, employer duty of care, occupational violence, reasonable precautions and causation.
What Was the Case About?
The plaintiff, Ms Frazer, was an experienced secondary school teacher employed by the State of Queensland.
The background to the case involved allegations made by students about Ms Frazer’s conduct. Ms Frazer denied wrongdoing and maintained that the relevant events were innocent. The Court noted that the criminal charges were dismissed and that Ms Frazer remained presumed innocent.
The claim arose from an incident at the school on 24 March 2021.
On that day, an aggrieved parent attended the school and said he was going to find and confront Ms Frazer. The principal sought assistance from deputy principals and the school-based police officer. The parent then attended near the staffroom where Ms Frazer was located. Ms Frazer alleged that the incident caused psychological injury.
The Main Issue
The main issue was whether the State of Queensland, as employer, breached its duty of care to Ms Frazer.
The State admitted that it owed Ms Frazer a non-delegable duty of care to take reasonable care for her safety in the course of her employment.
The question was whether the State had failed to take reasonable precautions against the risk of injury.
The Risk Considered by the Court
The Court considered whether the risk of injury to a teacher from an angry parent was foreseeable and not insignificant.
The Court accepted that the risk was foreseeable. The school was large, had many students and staff, and had policies dealing with occupational violence, hostile people on school premises and trespass procedures.
However, establishing that a risk is foreseeable is not enough. The Court also had to consider whether a reasonable person in the employer’s position would have taken the precautions identified by the plaintiff.
The Precautions Argued
The plaintiff relied on three main precautions.
These were:
- Using physical force to restrain or eject the parent from the school;
- Activating a lockdown;
- Warning Ms Frazer by telephone or another communication method.
The Court considered each proposed precaution separately.
Physical Restraint or Ejection
The Court did not accept that a reasonable person would have used physical force to restrain or eject the parent in the circumstances.
The Court considered the situation was highly charged and occurred in the presence of students, staff and the parent’s child. The school-based police officer considered de-escalation to be the better approach.
The Court accepted that physical force may be appropriate in some situations, but found it was not a reasonable precaution in the circumstances of this case.
Lockdown Procedure
The Court also considered whether the principal should have activated a school lockdown.
The incident occurred just before the first teaching period, when many students were outside classrooms. The Court considered that activating a lockdown at that time may have caused teachers to leave staffrooms to gather students, potentially increasing the risk to staff.
The Court found that a reasonable person in the principal’s position would not have activated the lockdown alarm in the circumstances.
Warning the Plaintiff
The plaintiff also argued that Ms Frazer should have been warned by telephone or another communication method.
The Court considered the very short timeframe involved. The evidence suggested there was only about one to two minutes between the parent leaving the administration area and arriving at the staffroom.
The principal immediately sent two deputy principals to the staffroom, contacted the school-based police officer, and also attended the area himself.
The Court considered that sending staff to attend the staffroom in person was a reasonable response. The Court was not satisfied that a reasonable person would have telephoned the staffroom or Ms Frazer instead.
Causation
The Court also considered causation.
Even if breach had been established, the plaintiff still needed to prove that the breach was a necessary condition of the injury.
The Court considered the plaintiff’s psychiatric evidence and the circumstances of the incident. It concluded that the alleged breaches had not been shown to be necessary conditions of the psychological injury.
This part of the decision is useful because it shows that psychological injury cases may involve careful analysis of multiple events, stressors and alleged precautions.
The Court’s Decision
The Court found that Ms Frazer had not proved breach of duty.
The Court also found that causation had not been established in relation to the alleged precautions.
As a result, judgment was entered for the State of Queensland.
Damages Assessment
Although the plaintiff did not succeed on liability, the Court still assessed damages. The Court assessed the plaintiff’s damages at $678,307.30.
This did not result in an award to the plaintiff, because judgment was entered for the defendant.
Why This Case Is Useful
This case is useful because it shows that workplace psychological injury matters often involve more than the existence of distressing events.
The Court may need to consider:
- What risk was foreseeable;
- What policies and procedures existed;
- What decisions were made in real time;
- What precautions were reasonable in the circumstances;
- Whether another response may have increased risk;
- Whether the alleged breach caused the injury;
- Whether multiple stressors contributed to the condition.
Practical Takeaway
The key takeaway from this case is that employer duty of care is assessed by reference to what was reasonable in the circumstances at the time.
In urgent workplace situations, courts may closely examine the time available to make decisions, the competing risks involved, and whether proposed precautions would likely have avoided the injury.
The case also shows that psychological injury claims may turn heavily on causation. It may not be enough to show that a distressing incident occurred. The evidence must also establish the necessary connection between the alleged breach of duty and the injury.
The information on this page is general in nature and does not constitute legal advice.