Jones Bros., Inc. v. Alabama Department of Transportation

Summary

The Alabama Supreme Court granted the Alabama Department of Transportation’s petition for a writ of mandamus and directed the trial court to dismiss the plaintiffs’ action. The court held that ALDOT, as a state agency, was absolutely immune from suit under Article I, § 14 of the Alabama Constitution, and that the immunity deprived the trial court of subject-matter jurisdiction. The court further stated that the plaintiffs had not named a proper state official as a defendant.

Holdings

1. ALDOT, as an agency of the State of Alabama, is absolutely immune from suit under Article I, § 14, of the Alabama Constitution when named as the defendant.
2. Because Article I, § 14, deprived the trial court of subject-matter jurisdiction over the action against ALDOT, the trial court was required to dismiss the complaint and could not proceed with the action or require an amendment.
3. Mandamus was an appropriate remedy for reviewing the trial court's order denying ALDOT's claim of State immunity, and ALDOT was entitled to the writ.

Questions Presented

1. Whether ALDOT, as a State agency, was absolutely immune from the plaintiffs' action under Article I, § 14, of the Alabama Constitution.
2. Whether the trial court lacked subject-matter jurisdiction over an action naming ALDOT as the defendant and therefore was required to dismiss the complaint.
3. Whether mandamus was an appropriate remedy to review the trial court's denial of ALDOT's immunity-based motions to dismiss.

Disposition

writ_granted