DeStafney v. University of Alabama
413 So.2d 391 (1982)
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Rule of Law:
Sovereign immunity under the Alabama Constitution does not extend to a state employee sued in their individual capacity for negligence committed within the scope of employment when the employee's actions are ministerial rather than discretionary, and when a judgment against the employee would not directly affect a contract or property right of the state.
Facts:
- The University of Alabama, a state institution, operated a day care facility called the Rose Towers Learning Center.
- Gabrielle Martinez was employed as an Aide at the day care center.
- Three-year-old Joseph Michael DeStafney was a student enrolled at the center.
- While under Martinez's care, Martinez placed DeStafney on a piece of playground equipment.
- DeStafney fell from the equipment and sustained a severe jaw injury.
- The injury was potentially permanent and could require multiple future surgical operations.
Procedural Posture:
- Jan Elizabeth DeStafney sued Gabrielle Martinez, the University of Alabama, and its president, David Mathews, in the Alabama Circuit Court (trial court).
- The defendants filed a motion for summary judgment, claiming sovereign immunity under the Alabama Constitution.
- The trial court granted summary judgment in favor of all defendants.
- DeStafney (appellant) appealed the trial court's decision to the Supreme Court of Alabama.
- The Supreme Court of Alabama initially affirmed the trial court's judgment in a per curiam opinion.
- DeStafney (appellant) filed an application for rehearing with the Supreme Court of Alabama.
- The Supreme Court granted rehearing to reconsider the claim against the individual defendant, Gabrielle Martinez.
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Issue:
Does the sovereign immunity afforded to the state and its agencies by § 14 of the Alabama Constitution extend to a state employee for an alleged act of simple negligence committed within the scope of her employment, where the relief sought is damages against the employee individually?
Opinions:
Majority - Justice Jones
No. The sovereign immunity provided by the Alabama Constitution does not extend to the state employee in this case. A claim for personal injury based upon the alleged negligent conduct of a state employee, even when committed in the line and scope of employment, is not within the ambit of § 14's protection because such a suit is not, in effect, a suit against the state. The court reasoned that a suit is against the state only when a result favorable to the plaintiff would directly affect a contract or property right of the state. Here, the suit is strictly between the plaintiffs and the individual defendant, Martinez, and any state interest is too incidental to provide constitutional immunity. The court further distinguished this case from prior precedent by explaining that immunity protects officials performing discretionary functions, not employees performing ministerial tasks. The act of placing a child on playground equipment is not a discretionary public function that public policy requires be immunized from liability.
Analysis:
This decision significantly clarifies the scope of state-agent immunity in Alabama by distinguishing between the absolute immunity of the state and the qualified immunity of its employees. It prevents the doctrine of sovereign immunity from becoming an absolute shield for any government employee's negligence. The ruling establishes a crucial distinction between discretionary functions, which may be immune, and ministerial acts, which are not. This forces future courts to analyze the specific nature of an employee's actions, rather than just their employment status, ensuring a potential remedy for individuals harmed by the ordinary negligence of state employees performing everyday tasks.
