Lallas v. Skagit County

225 P.3d 910, 167 Wash. 2d 861 (2009) · Supreme Court of Washington · December 31, 2009 · No. No. 81672-7

Summary

The Supreme Court of Washington held that a sheriff's deputy who escorted a prisoner to jail was performing a ministerial rather than judicial function. Accordingly, judicial immunity did not shield the deputy from tort liability, and the court affirmed the reversal of summary judgment for the deputy and Skagit County. The court did not decide whether judicial immunity could be imputed to the county.

Court
Supreme Court of Washington
Writing for the Court
Fairhurst, J.; Gerry L. Alexander, C.J.; Susan Owens, J.; Charles W. Johnson, J.; Barbara A. Madsen, J.; James M. Johnson, J.; Richard B. Sanders, J.; Debra L. Stephens, J.; Tom Chambers, J.
Jurisdiction
Washington
Decision date
December 31, 2009
Docket number
No. 81672-7
Procedural posture
Skagit County and Deputy Randall sought review of a Court of Appeals decision reversing summary judgment entered in their favor on the ground of judicial immunity.
Standard of review
Summary judgment is reviewed de novo; summary judgment is appropriate when there are no genuine issues of material fact and the moving party is entitled to judgment as a matter of law.
Precedential value
Published Washington Supreme Court en banc opinion; precedential
Parties
Skagit County, Deputy Deanna Randall v. John T. Lallas, Irene Lallas
Disposition
affirmed

Topics

summary judgmentmunicipal liabilitytortscivil procedure

Practice areas

TortsCivil ProcedureMunicipal Law

Questions Presented

  1. Whether Deputy Randall was entitled to judicial immunity from tort liability for escorting a prisoner to jail pursuant to a judge's directive.
  2. Whether Skagit County was entitled to judicial immunity based on Deputy Randall's conduct.

Holdings

  1. Judicial immunity does not shield Deputy Randall from tort liability because transporting a prisoner to jail is a ministerial, rather than judicial, function that judges do not normally perform as part of their official duties.
  2. The court did not decide whether judicial immunity could be imputed to Skagit County because Deputy Randall was not entitled to judicial immunity.

Key quotations

“Judges do not normally escort prisoners to jail as part of their official duties. Therefore, escorting a prisoner to jail is not a judicial function.” (at 913)
“Because transporting a prisoner is not something a judge normally does as part of his or her official duties, it is not judicial conduct.” (at 913)

Factual background

Deputy Deanna Randall, a sheriff's deputy serving as a court rover, was summoned by a district court judge to escort Anthony Reijm to jail. While Randall and Reijm waited for an elevator, Reijm broke free and ran toward the building entrance, where private security guard John Lallas attempted to stop him. Reijm struck Lallas, causing injuries, and the Lallases sued Randall and Skagit County for negligence.

Procedural history

The Lallases sued Deputy Randall, Skagit County, and Anthony Reijm for negligence after Reijm injured John Lallas while fleeing from Deputy Randall. The trial court granted summary judgment to Randall and the County based on judicial immunity. The Court of Appeals reversed, and the Supreme Court of Washington granted review and affirmed the Court of Appeals.

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