Brown v. Penland Const. Co., Inc., 281 Ga. 625

Summary

The Supreme Court of Georgia held that a high school baseball coach was not personally liable to a construction company under quantum meruit for an indoor baseball facility built for the school. Any implied promise of payment arose from the Board of Education's acceptance of the facility, not from the coach's individual acceptance, and official immunity would also bar the claim absent willful, malicious, or wanton conduct. The court reversed the relevant portion of the Court of Appeals' decision.

Holdings

1. A public official is protected by official immunity from an individual-capacity claim arising from discretionary acts within the scope of the official's authority absent wilful or wanton conduct, actual malice, or actual intent to cause injury. Because no such conduct was alleged, Brown's individual-capacity quantum meruit claim was barred if he acted within his authority.
2. A quantum meruit claim for construction services does not lie against an individual who did not individually accept the services and was not the person or entity expected to pay for them.
3. Evidence that a public-school coach worked in or benefited from a school facility did not establish that he received a special personal benefit supporting individual liability for the facility's construction cost.

Questions Presented

1. Whether Brown was protected by official immunity from PCC's individual-capacity quantum meruit claim.
2. Whether Brown could be personally liable in quantum meruit when he did not individually accept PCC's services or make an implied promise to pay for the facility.
3. Whether the alleged personal benefit to Brown supported liability for the construction cost.

Disposition

reversed