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Autonomous vehicle (AV) developers test extensively on public roads, potentially putting other road users at risk. A safety case for human supervision of road testing could improve safety transparency. A credible safety case should include: (1) the supervisor must be alert and able to respond to an autonomy failure in a timely manner, (2) the supervisor must adequately manage autonomy failures, and (3) the autonomy failure profile must be compatible with effective human supervision. Human supervisors and autonomous test vehicles form a combined human-autonomy system, with the total rate of observed failures including the product of the autonomy failure rate and the rate of unsuccessful failure mitigation by the supervisor. A difficulty is that human ability varies in a nonlinear way with autonomy failure rates, counter-intuitively making it more difficult for a supervisor to assure safety as autonomy maturity improves.