In Clevinger v. Board of Educ. of Pike County, Ky., 789 S.W.2d 5, 10 (1990) the Court noted that "at least since 1941 this Court has recognized that a County Board of Education is an arm of state government, and as such enjoys state sovereign immunity against liability and tort." In that case, the Court found that sovereign immunity protected the school board from being sued for declining to withdraw union dues from employees' paychecks.