Ex Parte Donaldson, 1100768 (Ala. 9-16-2011), 80 So. 3d 895

Jemison sued Deputy Donaldson, Sheriff Huffman, the Dallas County Sheriff's Department, and the Dallas County Commission for various tort claims arising from a 2008 motor vehicle collision.
The circuit court dismissed claims against the Department and the Commission, but allowed claims against Donaldson and Huffman to proceed, providing no explanation for the latter's denial.
Donaldson and Huffman sought a writ of mandamus to compel dismissal of the claims against them based on State immunity and State-agent immunity.
The case centers on whether sheriffs and deputy sheriffs are immune from monetary damages in their individual capacities when acting within the line and scope of employment.
The court must determine if Jemison’s allegations show acts within the line and scope of employment to trigger State immunity for Donaldson and Huffman.
The opinion ultimately grants the mandamus, holding Deputy Donaldson is entitled to State immunity and the trial court erred by not dismissing the claims against him and Huffman.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Deputy Donaldson enjoys State immunity for the incident.	Jemison argues Cranman-style immunity applies; not limited to line-of-duty acts.	Donaldson asserts State immunity applies because acts occurred within line and scope of employment as deputy.	Deputy Donaldson entitled to State immunity; claims against him barred.
Whether Sheriff Huffman is shielded by State immunity for the incident.	Jemison's assertions implicate Huffman in duties within employment scope.	Huffman, as a constitutional officer, is immune for acts within line and scope of his duties.	Huffman also entitled to State immunity; circuit court should have dismissed his claims.
Whether State-agent immunity analysis is controlling for deputies vs. State immunity.	Cranman framework should govern all immunity determinations for state actors.	State immunity and State-agent immunity are distinct; sheriffs/deputies qualify for State immunity, not Cranman-based State-agent immunity here.	State immunity applies; Cranman analysis is not controlling for deputy immunity in this context.

Ex parte Wood, 852 So. 2d 705 (Ala. 2002) (mandamus framework for necessary dismissal when immunity applies)
Ex parte United Serv. Stations, Inc., 628 So. 2d 501 (Ala. 1993) (original mandamus authority cited)
Ex parte Blankenship, 893 So. 2d 303 (Ala. 2004) (sovereign immunity bars money damages)
Newman v. Savas, 878 So. 2d 1147 (Ala. 2003) (no presumption of correctness on dismissal rulings)
Ex parte Haralson, 853 So. 2d 928 (Ala. 2003) (sheriffs as executive officers immune in line-and-scope acts)
Ex parte Davis, 930 So. 2d 497 (Ala. 2005) (State immunity where acts within line and scope of employment)
Shelley v. 53 So. 3d 887, 53 So. 3d 887 (Ala. 2009) (extends sheriff/deputy immunity; alter ego analysis)
Suttles v. Roy, So. 3d (Ala. 2010) (discusses distinction between State immunity and State-agent immunity)