Williams v. City of Midfield

Summary

The Alabama Supreme Court granted a petition for a writ of mandamus and directed the Jefferson Circuit Court to enter summary judgment for the City of Midfield and two police officers. The court held that the officers were entitled to State-agent immunity under Ala. Code § 6-5-338(a) for discretionary conduct during a police pursuit, and that the city was likewise immune from the related negligence claims. The court concluded that the plaintiffs had not presented substantial evidence showing that the officers acted beyond their authority or violated detailed rules or regulations.

Holdings

1. The officers were entitled to State-agent immunity because their alleged conduct occurred while they were performing discretionary law-enforcement functions within the line and scope of their duties, and the plaintiffs failed to show that an exception to immunity applied.
2. Because Officer Davis and Sgt. Brown were immune under § 6-5-338(a), Midfield was also immune from the negligence and negligence-per-se claims arising from the officers' conduct.
3. Midfield was not entitled to summary judgment on the negligent-training-and-supervision claim because it did not identify the individuals responsible for training and supervising the officers or establish that those individuals were themselves entitled to State-agent immunity.

Questions Presented

1. Whether Officer Davis and Sgt. Brown were entitled to State-agent immunity under Ala. Code § 6-5-338(a) for conduct undertaken while pursuing Marvin Brown.
2. Whether the plaintiffs presented substantial evidence that either officer acted beyond his authority by violating detailed pursuit-policy requirements or Ala. Code § 32-5A-7.
3. Whether Midfield was immune from the negligence and negligence-per-se claims because its officers were immune.
4. Whether Midfield was entitled to summary judgment on the negligent-training-and-supervision claim merely because the individual officers were immune.

Disposition

writ_granted