test for State-agent immunity (Alabama) · Go Syfert
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test for State-agent immunity in Alabama

25 Alabama opinions name it 2 courts 2001–2025 4 in the last five years

The cases below were cited by Alabama courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (10)

CaseFollowedCited
Ex Parte Cranmangreen
ala · 2000 · cited in 22 Alabama opinions naming this issue, 2001–2025
2 sentences

2025The test for State-agent immunity was established by a plurality of this Court in 2000 in Ex parte Cranman, 792 So. 2d 392 (Ala. 2000), and was adopted by a majority of this Court later that year in Ex parte Butts, 775 So. 2d 173 (Ala. 2000).

2025However, under the test for State-agent immunity, "not all discretionary acts by an agent of the State should be labeled as ' "immune." ' " Id. at 456 (quoting Ex parte Cranman, 792 So. 2d at 405 ).

222
Hollis v. City of Brightongreen
ala · 2006 · cited in 8 Alabama opinions naming this issue, 2010–2025
2 sentences

2025Specifically, " 'peace officers are afforded immunity by Ala. Code 1975, § 6-5-338(a), and the test for State- agent immunity set forth in Ex parte Cranman, 792 So. 2d 392 (Ala. 2000), as modified in Hollis v. City of Brighton, 950 So. 2d 300 (Ala. 2006) (incorporating the peace-officer-immunity standard provided in § 6-5-338(a) into the State- agent-immunity analysis found in Cranman)....

2024Specifically, 6 SC-2023-0735 " 'peace officers are afforded immunity by Ala. Code 1975, § 6-5-338(a), and the test for State- agent immunity set forth in Ex parte Cranman, 792 So. 2d 392 (Ala. 2000), as modified in Hollis v. City of Brighton, 950 So. 2d 300 (Ala. 2006) (incorporating the peace-officer-immunity standard provided in § 6-5-338(a) into the State- agent-immunity analysis found in Cranman)....

28
Ex Parte Buttsgreen
ala · 2000 · cited in 10 Alabama opinions naming this issue, 2001–2025
2 sentences

2025The test for State-agent immunity was established by a plurality of this Court in 2000 in Ex parte Cranman, 792 So. 2d 392 (Ala. 2000), and was adopted by a majority of this Court later that year in Ex parte Butts, 775 So. 2d 173 (Ala. 2000).

2024Discussion The test for State-agent immunity set forth in Ex parte Cranman, 792 So. 2d 392 (Ala. 2000)(plurality opinion), which was adopted by the Court in Ex parte Butts, 775 So. 2d 173 (Ala. 2000), provides that a State agent is entitled to immunity from civil liability for negligence alleged to have occurred while the State agent was engaged in certain conduct.

110
Ex Parte Duvallgreen
ala · 2000 · cited in 2 Alabama opinions naming this issue, 2002–2002
2 sentences

2002Ex parte Duvall, 782 So.2d 244, 248 (Ala.2000).

2002Ex parte Duvall , 782 So.2d 244 , 248 (Ala. 2000).

12
Oyedepo v. Sellersgreen
ala · 2013 · cited in 1 Alabama opinions naming this issue, 2025–2025
1 sentence

2025Nevertheless, the Court cited those cases for the principle that "the performance of jobs in areas other than the classroom involves the 'supervising and educating of students.' " Ex parte Mason, 146 So. 3d at 13 (citation omitted).

11
Ex Parte Kennedygreen
· 2008 · cited in 1 Alabama opinions naming this issue, 2010–2010
1 sentence

2010See Ex parte Kennedy, 992 So.2d 1276 (Ala.2008), and City of Birmingham v. Brown, 969 So.2d 910, 916 (Ala.2007) (“Immunity applies to employees of municipalities in the same manner that immunity applies to employees of the State.” (citing Cranman, supra)).

11
City of Birmingham v. Browngreen
ala · 2007 · cited in 1 Alabama opinions naming this issue, 2010–2010
1 sentence

2010See Ex parte Kennedy, 992 So.2d 1276 (Ala.2008), and City of Birmingham v. Brown, 969 So.2d 910, 916 (Ala.2007) (“Immunity applies to employees of municipalities in the same manner that immunity applies to employees of the State.” (citing Cranman, supra)).

11
City of Birmingham v. Sutherlandgreen
ala · 2002 · cited in 1 Alabama opinions naming this issue, 2006–2006
2 sentences

2006See also City of Birmingham v. Sutherland , 834 So.2d 755 , 762 (Ala. 2002).

2006See also City of Birmingham v. Sutherland, 834 So.2d 755, 762 (Ala. 2002).

11
Ex Parte Turnergreen
ala · 2002 · cited in 1 Alabama opinions naming this issue, 2006–2006
2 sentences

2006See Ex parte Turner , 840 So.2d 132 , 136 (Ala. 2002)(`"a State agent shall not be immune from civil liability in his or her personal capacity . . . (2) when the State agent acts willfully, maliciously, fraudulently, in bad faith, beyond his or her authority, or under a mistaken interpretation of the law."' (quoting Ex parte Cranman , 792 So.2d 392 , 405 (Ala. 2000))). "2 The test for State-agent immunity, as discussed in Ex parte Cranman , 792 So.2d 392 (Ala. 2000), and adopted by a majority of this Court in Ex parte Butts , withholds immunity from State agents acting in their personal capaci

2006See Ex parte Turner, 840 So.2d 132, 136 (Ala.2002)(`"a State agent shall not be immune from civil liability in his or her personal capacity . . . (2) when the State agent acts willfully, maliciously, fraudulently, in bad faith, beyond his or her authority, or under a mistaken interpretation of the law."' (quoting Ex parte Cranman, 792 So.2d 392, 405 (Ala. 2000))). "2 The test for State-agent immunity, as discussed in Ex parte Cranman, 792 So.2d 392 (Ala.2000), and adopted by a majority of this Court in Ex parte Butts, withholds immunity from State agents acting in their personal capacity, `"wh

11
Gary v. Crouchgreen
ala · 2003 · cited in 1 Alabama opinions naming this issue, 2006–2006
2 sentences

2006See Ex parte Turner , 840 So.2d 132 , 136 (Ala. 2002)(`"a State agent shall not be immune from civil liability in his or her personal capacity . . . (2) when the State agent acts willfully, maliciously, fraudulently, in bad faith, beyond his or her authority, or under a mistaken interpretation of the law."' (quoting Ex parte Cranman , 792 So.2d 392 , 405 (Ala. 2000))). "2 The test for State-agent immunity, as discussed in Ex parte Cranman , 792 So.2d 392 (Ala. 2000), and adopted by a majority of this Court in Ex parte Butts , withholds immunity from State agents acting in their personal capaci

2006See Ex parte Turner, 840 So.2d 132, 136 (Ala.2002)(`"a State agent shall not be immune from civil liability in his or her personal capacity . . . (2) when the State agent acts willfully, maliciously, fraudulently, in bad faith, beyond his or her authority, or under a mistaken interpretation of the law."' (quoting Ex parte Cranman, 792 So.2d 392, 405 (Ala. 2000))). "2 The test for State-agent immunity, as discussed in Ex parte Cranman, 792 So.2d 392 (Ala.2000), and adopted by a majority of this Court in Ex parte Butts, withholds immunity from State agents acting in their personal capacity, `"wh

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Alabama. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
Ex Parte Estate of Reynolds green
ala · 2006
2 sentences

2025However, under the test for State-agent immunity, "not all discretionary acts by an agent of the State should be labeled as ' "immune." ' " Id. at 456 (quoting Ex parte Cranman, 792 So. 2d at 405 ).

2017"This Court, in [ Ex parte] Cranman [, 792 So.2d 392 (Ala. 2000) ], stated the test for State-agent immunity as follows: " 'A State agent shall be immune from civil liability in his or her personal capacity when the conduct made the basis of the claim against the agent is based upon the agent's " '(1) formulating plans, policies, or designs; or " '(2) exercising his or her judgment in the administration of a department or agency of government, including, but not limited to, examples such as: " '(a) making administrative adjudications; " '(b) allocating resources; " '©) negotiating contracts; "

22017–2025
Berry v. City of Montgomery green
ala · 2012
1 sentence

2017"This Court, in [ Ex parte] Cranman [, 792 So.2d 392 (Ala. 2000) ], stated the test for State-agent immunity as follows: " 'A State agent shall be immune from civil liability in his or her personal capacity when the conduct made the basis of the claim against the agent is based upon the agent's " '(1) formulating plans, policies, or designs; or " '(2) exercising his or her judgment in the administration of a department or agency of government, including, but not limited to, examples such as: " '(a) making administrative adjudications; " '(b) allocating resources; " '©) negotiating contracts; "

12017–2017
Gaither v. Advertiser Co. green
ala · 1893
1 sentence

2003Gary does discuss a warning she received when she allowed her child to ride in her patrol car, but she said in her deposition that she was not formally reprimanded for having done so. 4 "'Words are actionable which directly tend to the prejudice of any one in his office, profession, trade, or business, in any lawful employment by which he may gain his livelihood.'" Gaither, 102 Ala. at 463 , 14 So. at 789 (quoting Ostrom v. Calkins, 5 Wend. 263 (N.Y. 1830)). 5 Phillips presented an example of invasion of privacy by means of intrusion upon seclusion; in that case a supervisor repeatedly demande

12003–2003
Ostrom v. Calkins neutral
· 1830
1 sentence

2003Gary does discuss a warning she received when she allowed her child to ride in her patrol car, but she said in her deposition that she was not formally reprimanded for having done so. 4 "'Words are actionable which directly tend to the prejudice of any one in his office, profession, trade, or business, in any lawful employment by which he may gain his livelihood.'" Gaither, 102 Ala. at 463 , 14 So. at 789 (quoting Ostrom v. Calkins, 5 Wend. 263 (N.Y. 1830)). 5 Phillips presented an example of invasion of privacy by means of intrusion upon seclusion; in that case a supervisor repeatedly demande

12003–2003

Statutes the citing opinions construe

AL § Ala. Code § 6-5-338 (10) AL § Ala. Code § 32-5A-7 (6) USC § 42u.s.c.1983 (5) AL § Ala. Code § 32-5-213 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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