International Business Machines Corp. v. Evans

Summary

The Georgia Supreme Court held that sovereign immunity did not bar IBM's action seeking injunctive relief against the Georgia Department of Administrative Services and its commissioner. The court recognized an exception for actions seeking to restrain illegal conduct by state officials and remanded for consideration of whether DOAS violated the terms of its request for proposals in evaluating IBM's bid. The court emphasized that judicial interference is permitted only under demanding standards, including action wholly outside statutory authority, arbitrary or capricious decision-making, clear error, or violation of constitutional rights.

Holdings

1. Sovereign immunity does not bar a suit seeking injunctive relief to restrain an illegal act by the state or a public official acting outside the scope of lawful authority.
2. The 1991 amendment to the Georgia Constitution did not eliminate the longstanding exception to sovereign immunity for actions seeking injunctive relief against illegal state action.
3. The complaint was not barred by sovereign immunity, and the case had to be remanded for the trial court to determine whether DOAS acted without lawful authority or beyond the scope of its official power by allegedly violating the RFP.

Questions Presented

1. Whether sovereign immunity bars IBM's action seeking injunctive relief against DOAS and its commissioner in his official capacity to restrain an allegedly unlawful state-contract award.
2. Whether the alleged violation of the RFP could support injunctive relief under the standard governing judicial interference with state administrative action.
3. Whether the 1991 amendment to the Georgia Constitution eliminated the longstanding exception to sovereign immunity for suits seeking to enjoin illegal official action.

Disposition

reversed_and_remanded