Summary
The Alabama Supreme Court granted Marcus Lydell Walker’s petition for a writ of mandamus and directed the Macon Circuit Court to dismiss claims arising from an automobile accident. The court held that, because the complaint alleged Walker was acting within the line and scope of his employment as a deputy sheriff, he was immune from suit under Article I, § 14, of the Alabama Constitution. The court distinguished an earlier case where the pleadings did not establish that the deputy was acting within the scope of employment.
Topics
Practice areas
Questions Presented
- Whether Walker was entitled to State immunity under Article I, § 14, of the Alabama Constitution based solely on the complaint's allegations that he was acting within the line and scope of his employment as a deputy sheriff.
- Whether the Macon Circuit Court erred by denying Walker's Rule 12(b)(6) motion to dismiss and whether mandamus was an appropriate remedy.
Holdings
- Because Harris alleged that Walker was acting within the line and scope of his employment and in the regular course and scope of his employment as a deputy sheriff at the time of the accident, those allegations had to be accepted as true on a Rule 12(b)(6) motion. The allegations therefore established that Walker was immune from suit under Article I, § 14.
- Walker demonstrated a clear legal right to dismissal of the claims asserted against him, and the Supreme Court of Alabama granted the petition and issued the writ of mandamus directing the Macon Circuit Court to dismiss those claims.
Key quotations
“Because Harris himself alleged in the complaint that Walker was “acting within the line and scope of his employment” as a deputy sheriff and “was engaged in the regular course and scope of his employment for the Macon County Sheriffs Department” at the time of the accident, Walker is immune from suit pursuant to § 14.” (at 753)
“PETITION GRANTED; WRIT ISSUED.” (at 753)
Factual background
On April 9, 2011, Marcus Lydell Walker, a Macon County sheriff's deputy, was involved in a vehicle collision with Miguel Harris. Harris's complaint alleged twice that Walker was acting within the line and scope of his employment and in the regular course and scope of his employment at the time of the accident. Harris asserted negligence, wanton and reckless conduct, and negligent and wanton entrustment against Walker and the county defendants.
Procedural history
Harris sued Walker, the Macon County Commission, and Macon County after a vehicle collision, asserting negligence, wanton and reckless conduct, and negligent and wanton entrustment. The defendants moved to dismiss. The Macon Circuit Court dismissed the claims against the county defendants but denied Walker's motion to dismiss. Walker then sought mandamus relief in the Supreme Court of Alabama.
Remand instructions
The Macon Circuit Court was directed to dismiss the claims asserted against Walker.