Board of School Commissioners v. Weaver, 99 So. 3d 1210

Bridget Weaver sued the Board and Superintendent Nichols in 2009 for declaratory judgment, mandamus, and injunctive relief over a reduction-in-force policy.
Weaver claimed policy 6.44 granted a one-time recall right to a certified and legally qualified position after a RIF.
May 2008 actions implemented RIF with recalls affecting central administration; Weaver and others alleged less senior colleagues were recalled ahead of them.
Interventions by Dickinson and Reese were allowed; the case proceeded through summary-judgment and ore tenus trial, resulting in findings and a bench judgment in 2011.
The trial court awarded backpay, reinstatement to assistant-principal positions as available, retirement-benefit credits, and interest; amended judgment issued August 2011.
The Board appealed, challenging jurisdiction under state immunity; the court of appeals ultimately dismissed for lack of subject-matter jurisdiction due to §14 immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Board is immune under §14	Weaver argues claims seek monetary and injunctive relief against a State agency.	Board contends §14 immunity bars suit against the State and its agencies.	Board has absolute immunity; claims against Board are barred.
Whether Nichols in official capacity is immune under §14	Weaver seeks relief directed at Nichols’ official acts under the policy.	Nichols argues §14 immunity shields him when sued only in his official capacity.	Nichols is entitled to §14 immunity; official-capacity claims are void.
Whether the action falls within any §14 immunity exceptions	Action seeks to compel legal duties/ministerial acts under the May 9 letter.	Exceptions do not apply because Board, not Nichols, had the power to grant relief.	No §14 exceptions apply; immunity applies.

Ex parte Monroe County Bd. of Educ., 48 So.3d 621 (Ala. 2010) (state immunity discussions for §14 with Board as State actor)
Ex parte Bessemer Bd. of Educ., 68 So.3d 782 (Ala. 2011) (ministerial acts vs. actions against the State; Board members’ duties)
Harbert International, Inc. v. Ala. Dept. of Transp., 990 So.2d 831 (Ala. 2008) (state officer immunity; when mandamus lies; ministerial vs. discretionary acts)
Ex parte Citizens Bank, 879 So.2d 535 (Ala. 2003) (void judgments and appellate dismissal under immunity context)
Haley v. Barbour County, 885 So.2d 783 (Ala. 2004) (state-immunity framework for county boards of education)
Ex parte Carter, 395 So.2d 65 (Ala. 1980) (limitations on §14 scope regarding particular types of actions)
McDowell-Purcell, Inc. v. Bass, 370 So.2d 942 (Ala. 1979) (mandamus scope and ministerial duties language cited in §14 discussion)