Ex parte Goodwin, [Ms. SC-2025-0116, Sept. 12, 2025] __ So. 3d __ (Ala. 2025). The Court (Lewis, J.; Stewart, C.J., and Wise, Sellers, Mendheim, and McCool, JJ., concur; Shaw, J., concurs in the result, with opinion, which Cook, J., joins; Bryan, J., concurs in the result) grants in part and denies in part a mandamus petition filed by Jeff Goodwin, in his official capacity as president of Northwest Shoals Community College (“NSCC”). The Court directs the Franklin Circuit Court to dismiss the official capacity claims against Goodwin asserted by Anthony Shackelford and Kimberly Y. Miller, former professors at NSCC, seeking backpay and attorney fees. The Court denies the petition as to the former professors’ claims for declaratory and injunctive relief.
The former professors sought a judgment “(1) declaring that NSCC and its former president had failed to comply with the Students First Act, § 16-24C-1 et seq., Ala. Code 1975, in implementing a reduction-in-force (“RIF”) policy; (2) reinstating them to their former positions; and (3) awarding them backpay, benefits, and attorney fees.” Ms. *5. The Court holds “[t]o the extent that the former professors seek monetary damages – an award of backpay, benefits, and attorney fees – their claims are clearly barred by State immunity because those damages would affect the state treasury.” Ms. *10, citing Ex parte Wilcox Cnty. Bd. of Educ., 279 So. 3d 1135, 1142 (Ala. 2018).
The Court concludes the claims “seek[ing] a judgment declaring [their] rights under [the Students First Act] and injunctive relief in the form of reinstatement … satisfy, at least, the fourth and sixth exceptions recognized in Ex parte Wilcox County Board of Education.” Ms. *11. The Court explains “‘the claim for declaratory relief falls within the fourth exception for ‘actions brought against State officials under the Declaratory Judgments Act, Ala. Code 1975, § 6-6-220 et seq., seeking construction of a statute and its application in a given situation.’” Ibid., quoting Ex parte Alabama Dep’t of Fin., 991 So. 2d 1254, 1257 (Ala. 2008). And “the claim for injunctive relief (i.e., reinstatement to their former positions) falls within the sixth exception for ‘actions for injunction brought against State officials in their representative capacity where it is alleged that they had acted fraudulently, in bad faith, beyond their authority, or in a mistaken interpretation of law.’” Ibid., quoting Ex parte Moulton, 116 So. 3d 1119, 1141 (Ala. 2006).