Alabama State Employees Ass'n v. Dickson

Summary

The Alabama Supreme Court denied a petition for a writ of mandamus filed by members of the State Personnel Board. The court held that the members had not established a clear legal right to immunity from claims seeking injunctive relief based on absolute legislative immunity, State immunity, or State-agent immunity. The court distinguished between legislative enactment and enforcement of the challenged amendment to Alabama’s deferred compensation plan.

Holdings

1. The Board members did not establish a clear legal right to absolute legislative immunity from claims seeking to enjoin enforcement of the amendment.
2. Section 14 did not bar the claims for injunctive relief because an action may be maintained against a state official acting beyond the scope of authority or illegally.
3. State-agent immunity did not require dismissal of the injunctive-relief claims.

Questions Presented

1. Whether the Board members established a clear legal right to dismissal of the claims for injunctive relief based on absolute legislative immunity.
2. Whether Alabama Constitution article I, § 14 barred the claims for injunctive relief against the Board members in their official capacities.
3. Whether State-agent immunity under Ex parte Cranman required dismissal of the remaining injunctive-relief claims.

Disposition

writ_denied