Sovereign Immunity - Ex Parte J. Christopher Murphy
In Ex parte J. Christopher Murphy, [Ms. 1090699, May 13, 2011] __ So. 3d __(Ala. 2011), the Alabama Supreme Court held that a class action seeking money damages from the State would affect the financial status of the State treasury and thus was barred by the doctrine of sovereign immunity. Plaintiffs brought a class action complaint alleging that the Alabama Department of Public Safety and its director overcharged citizens for renewals of driver's licenses and duplicate driver's licenses in violation of Ala. Code ¤¤ 32-6-4, 32-6-6, and 32-6-15. The Complaint included counts for declaratory and injunctive relief as well as unjust enrichment and unlawful taking. Plaintiffs sought money damages for the latter two counts. While the Court recognized that there is an exception to sovereign immunity where it is alleged that state officials in their representative capacity acted fraudulently, in bad faith, beyond their authority, or in a mistaken interpretation of the law, it noted that this exception is "qualified by the general principle that '[a]n action is one against the [S]tate [and is thus barred by the doctrine of sovereign immunity] when a favorable result for the plaintiff. . .would result in the plaintiff's recovery of money from the [S]tate'" (citations omitted). It was undisputed that plaintiffs sought money damages from the State with respect to their third and fourth counts. As a result, the Alabama Supreme Court held that to the extent the action sought money damages from the State, it was barred by the doctrine of sovereign immunity. Thus, the counts seeking money damages were dismissed.