Looking at the implementation on Wikipedia, it would seem that a standard BST (non self balancing) never re-arranges itself during inserts, and so the very first item added will always be the root. Is this correct? If so, doesn't that mean that there is the potential for a BST to often have much worse than O(logN)?
Using this as a reference for a recursive insert:
/* Inserts the node pointed to by "newNode" into the subtree rooted at "treeNode" */
void InsertNode(Node* &treeNode, Node *newNode)
{
if (treeNode == NULL)
treeNode = newNode;
else if (newNode->key < treeNode->key)
InsertNode(treeNode->left, newNode);
else
InsertNode(treeNode->right, newNode);
}