Hernandez v. Department of Human Resources of Alabama

Summary

The Alabama Supreme Court granted Hattie Randall’s petition for a writ of mandamus and directed the trial court to enter summary judgment in her favor based on State-agent immunity. Randall, a day-care licensing consultant, was sued in connection with the death of an infant who received toxic medications while attending a licensed day-care facility. The court analyzed Alabama’s State-agent immunity framework under Ex parte Cranman and the requirements for mandamus review of an immunity-based summary-judgment ruling.

Holdings

1. The denial of a motion for summary judgment grounded on immunity is reviewable by petition for a writ of mandamus.
2. Randall was entitled to State-agent immunity against claims arising from her evaluation of the day-care operator's written medication-authorization practices.
3. Randall was entitled to State-agent immunity against claims arising from her evaluation of the day-care facility's staffing and supervision.
4. The fraud claim failed as a matter of law because the Hernandezes presented no substantial evidence that Randall made a material misrepresentation on which they reasonably relied and that proximately caused injury.

Questions Presented

1. Whether denial of Randall's summary-judgment motion based on State-agent immunity was reviewable by petition for a writ of mandamus.
2. Whether Randall was entitled to State-agent immunity for her conduct in evaluating the day-care facility's medication-record practices and completing the licensing-evaluation form.
3. Whether Randall was entitled to State-agent immunity for her evaluation of the facility's staffing and supervision practices.
4. Whether the Hernandezes presented substantial evidence of fraud sufficient to withstand summary judgment.

Disposition

writ_granted