Ex parte Walley

Summary

The Supreme Court of Alabama considered whether state agencies and individual state officers sued in their official capacities were immune under Article I, § 14 of the Alabama Constitution from claims challenging an allegedly discriminatory employment transfer. The court held that the agencies were protected by sovereign immunity, but that the claims seeking declaratory and injunctive relief against the individual officers fell within recognized exceptions to immunity because the requested relief could result in reinstatement. The petition for a writ of mandamus was denied.

Holdings

1. The State of Alabama and its agencies are absolutely immune from suit in any court under Article I, § 14, of the Alabama Constitution.
2. State officers sued in their official capacities are not immune from an action seeking declaratory and injunctive relief that would require them to correct an allegedly illegal transfer and effectively reinstate the plaintiff.
3. The petition for a writ of mandamus must be denied because the petitioners did not establish a clear legal right to dismissal of the claims against the individual state officers.

Questions Presented

1. Whether the state agencies named as defendants were absolutely immune from suit under Article I, § 14, of the Alabama Constitution.
2. Whether state officers sued in their official capacities were immune under Article I, § 14, when the plaintiff sought declaratory and injunctive relief that would effectively reinstate her to her former state position.
3. Whether the petitioners established a clear legal right to a writ of mandamus directing dismissal of the action in its entirety.

Disposition

writ_denied