State-Agent Immunity


Ex parte Sonia Blunt, [Ms. 1180372, Dec. 6, 2019] __ So. 3d __ (Ala. 2019). In a per curiam opinion (Parker, C.J.; and Bolin, Shaw, Wise, Bryan, Sellers, Stewart, and Mitchell, JJ., concur; Mendheim, J., concurs specially), the Court issues a writ of mandamus to the Tuscaloosa Circuit Court directing the court to enter summary judgment, on grounds of state-agent immunity, in favor of Sonia Blunt, a teacher at Northridge High School in the Tuscaloosa City School System (TCS).

A short time after leaving Ms. Blunt’s summer school class, student Marcus Crawford “crossed a double yellow line to pass another vehicle, and collided with a vehicle driven by Susan Kines Langston, a TCS teacher, in which Matthew Langston and Joshua Langston were passengers. Susan Langston was killed in the accident and Matthew and Joshua were seriously injured ....” Ms. *5.

Langston contended that Blunt acted beyond her authority in allowing Crawford to leave the Northridge campus without checking out according to the procedure set out in a resource guide requiring that “[s]tudents who leave school for any reason must check out through the principal’s office.” Ms. *18. Blunt presented undisputed evidence from a number of witnesses that the checkout policy applied only during the academic year, not during the summer session. Ms. *19. Based on this evidence, the Court concluded that “Langston failed to demonstrate the existence of a detailed rule binding upon Blunt that would establish that she acted beyond her authority in supervising students when she allowed Crawford to leave Northridge at the time and in the manner he did on June 28, 2010. Therefore, Blunt was entitled to State-agent immunity from Langston’s claims of negligence and wantonness pertaining to her alleged violation of a TCS policy or procedure.” Ms. *35.

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