In Smith v. McDowell, 292 Ga. App. 731, 733 (666 SE2d 94) (2008) the Court reviewed recent decisions and indeed found that "a de facto absolute immunity for school employees had developed gradually across the last decade. Not one recent case existed in which the Georgia courts had found a ministerial duty on the part of a school employee." Id. at 734. After acknowledging that "other decisions of this court had stretched the concept of a discretionary act in school cases to its outermost limits," the Court determined that those decisions were factually distinguishable from Smith, where the school policy plainly had provided for no discretion. Id.