Baker v. Fields
543 S.W.3d 575
| Mo. Ct. App. | 2018Background
- Student Kamryn Baker sued school officials after slipping on black ice in the high school parking lot; only grounds crew members Lynn Fields and Bo Rains remained as defendants.
- Fields and Rains moved for summary judgment asserting qualified official immunity (and separately raised open-and-obvious, not appealed); the trial court denied immunity, concluding snow/ice removal is ministerial.
- Fields and Rains appealed interlocutorily to the Court of Appeals, limiting briefing and issues to qualified official immunity and whether duties were discretionary.
- The Court of Appeals agreed snow/ice removal is ministerial (no immunity) but went further and held Fields and Rains had no duty to remove the ice and thus were not negligent as a matter of law.
- The Kentucky Supreme Court granted discretionary review to decide whether the Court of Appeals exceeded the permissible scope of an interlocutory appeal addressing denial of qualified immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an interlocutory appeal from denial of qualified official immunity may include substantive negligence determinations | Baker argued the Court of Appeals improperly resolved negligence on interlocutory appeal; substantive issues remain for trial | Fields/Rains argued interlocutory review could resolve related substantive issues based on the record | The Court held interlocutory review is limited to whether immunity was properly denied; resolving negligence exceeded the scope and was improper |
| Whether snow/ice removal is ministerial or discretionary (as it relates to immunity) | Baker supported trial court: snow/ice removal is ministerial, so no immunity | Fields/Rains contended duties were discretionary, entitling them to immunity | The Court did not decide the merits anew; it accepted that the trial court treated removal as ministerial for purposes of the interlocutory appeal but emphasized that factual duty questions remain for the factfinder |
| Proper procedural posture for appeals of immunity denials | Baker: interlocutory appeal should be confined to immunity question | Defendants: interlocutory appeal could resolve broader legal issues when appropriate | Held that Prater permits interlocutory appeals of immunity denials but scope is confined to the immunity question only |
| Role of appellate courts in interlocutory immunity appeals | Baker: appellate courts must not bypass structured review to decide substantive claims | Defendants: appellate court may decide dispositive issues on the record | Held appellate courts must not decide additional substantive claims (e.g., negligence) on interlocutory immunity appeals; such matters return to trial court for adjudication |
Key Cases Cited
- Breathitt County Bd. of Educ. v. Prater, 292 S.W.3d 883 (Ky. 2009) (authorizes interlocutory appeals of immunity denials)
- Ratliff v. Fiscal Court of Caldwell County, 617 S.W.2d 36 (Ky. 1981) (discussion of interlocutory appeal contexts and final judgment rule)
- Commonwealth v. Samaritan Alliance, 439 S.W.3d 757 (Ky. App. 2014) (limits interlocutory review to immunity issue)
- Range v. Douglas, 763 F.3d 573 (6th Cir. 2014) (federal authority holding interlocutory immunity review limited to immunity question)
- Owensby v. City of Cincinnati, 414 F.3d 596 (6th Cir. 2005) (discusses limits on interlocutory appeals from immunity denials)
- Tucker v. City of Richmond, 388 F.3d 216 (6th Cir. 2004) (same)