212 So. 3d 112
Ala.2016Background
- Danley was hired as Alabama State University (ASU) athletic director under a fixed-term contract (July 26, 2010–Sept. 30, 2013) and was issued a university purchasing card with a payroll-deduction acknowledgement.
- He was placed on administrative leave (Aug. 28, 2012), and after a pre-termination hearing the hearing officer recommended termination; ASU terminated him effective Dec. 31, 2012.
- Danley sued under state law and 42 U.S.C. § 1983, alleging due-process violations (procedural defects in termination and post-termination procedures), wrongful seizure of December 2012 pay, and sought backpay, reinstatement, and attorney fees; ASU counterclaimed for unpaid purchasing-card charges.
- The trial court found Danley was not properly terminated, awarded backpay ($118,096.87) and an additional wrongful-withdrawal award ($22,120), and denied ASU’s counterclaim; Danley sought reinstatement and fees on cross-appeal.
- On appeal, the Alabama Supreme Court analyzed sovereign immunity under Art. I, § 14 (state-law claims), State-agent immunity (Cranman), Eleventh Amendment (federal claims), and qualified immunity for individual defendants; it affirmed denial of the counterclaim but vacated the monetary awards to the extent barred by immunity and reversed awards tied to federal claims against officials.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Art. I, § 14 sovereign immunity bars Danley’s state-law damages (backpay and wrongful-withdrawal) against ASU and officials sued in official capacity | Danley: exceptions (compel performance/ministerial acts/acts beyond authority) allow damages to enforce contractual pay and to remedy wrongful withdrawal | ASU: § 14 provides absolute immunity for monetary relief against the State and officials in official capacity | Court: § 14 bars state-law damages against ASU and officials in official capacity; monetary awards based on state-law claims against them are void and must be vacated |
| Whether individual officials (Knight, Harris) are immune from state-law claims under Cranman (State-agent immunity) | Danley: officials acted willfully/bad faith beyond authority in terminating him and ordering withdrawal; thus immunity inapplicable | Officials: their acts (supervision, personnel decisions) are discretionary and fit Cranman categories | Court: Contract (backpay) award is effectively against the State (vacated). Wrongful-withdrawal: conduct of Knight/Harris was supervisory/discretionary, so State-agent immunity applies to state-law claims and those awards must be vacated as to state-law basis |
| Whether Eleventh Amendment bars federal § 1983 damages against ASU and officials sued in official capacity; and whether Knight/Harris have qualified immunity on federal claims | Danley: federal claims recover damages; monetary relief appropriate on § 1983 due-process violations | ASU/officials: Eleventh Amendment bars official-capacity damages; Knight/Harris assert qualified immunity for individual-capacity federal claims | Court: Eleventh Amendment bars monetary relief against ASU and officials in official capacities (vacate awards). Knight/Harris are entitled to qualified immunity on the federal wrongful-withdrawal claim (vacated) because no causal supervisory involvement shown |
| Whether Danley is entitled to reinstatement and § 1988 attorney fees as prevailing party | Danley: prevailing on § 1983 entitles him to reinstatement and fees | ASU: procedural-due-process violation (improper process) does not necessarily mean wrongful discharge for an improper reason; no prevailing-party status if awards vacated | Court: Reinstatement denied — termination was procedurally defective but not shown to be for unconstitutional motive; Danley is not a prevailing party for § 1988 because damages awards are vacated and no injunctive relief granted |
Key Cases Cited
- State of Alabama Highway Department v. Milton Constr. Co., 586 So.2d 872 (Ala. 1991) (contract claim enforcement against state agency fits exception to sovereign immunity when state contracted for and accepted services)
- Ex parte Cranman, 792 So.2d 392 (Ala. 2000) (formulation of State-agent immunity test for individual-capacity state officials)
- Ex parte Moulton, 116 So.3d 1119 (Ala. 2013) (clarifies § 14 exceptions and that damages against officials are generally available only in individual capacity for bad-faith or ultra vires acts)
- Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S. 89 (U.S. 1984) (Eleventh Amendment bars suits seeking recovery of money from a state; official-capacity damages often function as suits against the state)
- Ex parte Alabama Dep’t of Fin., 991 So.2d 1254 (Ala. 2008) (enumeration of categories not considered actions "against the State" under § 14)
- Marous Bros. Constr., LLC v. Alabama State Univ., 533 F.Supp.2d 1199 (M.D. Ala. 2008) (federal district court applying Milton to deny ASU's sovereign-immunity dismissal in breach-of-contract context)