NTSB Probable Cause

FAILURE OF THE FLIGHT INSTRUCTOR/PILOT-IN-COMMAND TO ADEQUATELY SUPERVISE THE FLIGHT AND TO MAINTAIN ADEQUATE AIRSPEED BY EXCEEDING THE CLIMB PERFORMANCE OF THE AIRPLANE. CONTRIBUTING TO THE ACCIDENT WAS THE PILOT-IN-COMMAND'S INADEQUATE PLANNING AND HIS SELECTION OF AN IMPROPER ALTITUDE FOR FLIGHT INTO RISING TERRAIN DURING HIGH DENSITY ALTITUDE CONDITIONS.