History
  • No items yet
midpage
147 So. 3d 415
Ala.
2013
Read the full case

Background

  • Jones, a former PE teacher at Gresham Middle School, faced a May 5, 2006 basketball-area altercation between students Demetrius Hall and Michael Boyd; Demetrius sustained serious injuries.
  • Hall sued Jones and two other PE teachers for negligence and wantonness, alleging inadequate supervision.
  • Jones and Sokol answered asserting State-agent immunity; the defense sought summary judgment on immunity grounds.
  • The trial court denied Jones’s initial summary-judgment motion on December 19, 2011; Sokol and Queen later had their claims dismissed in January 2012.
  • Jones sought mandamus review in February 2012; this Court denied it as untimely, citing Rule 21(a)(3); Jones filed a renewed summary-judgment motion in November 2012, relying on Ex parte Montgomery County Board of Education (2012).
  • Following a hearing, the trial court again denied Jones’s renewed motion on April 2, 2013, prompting the current petition for mandamus.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Jones is entitled to State-agent immunity as a matter of law. Jones asserts immunity under Cranman and subsequent waivers. Hall argues material facts (presence on gym floor) negate immunity. No, immunity denial stands; no clear right to relief.
Whether Jones’s February 2012 mandamus petition was timely. Jones contends timely under Rule 21 and related authorities. Jones filed beyond the presumptively reasonable time without good cause. Untimely; petition denied.
Whether the renewed motion for summary judgment permitted mandamus review. Renewed motion identical in grounds; warrants review. Renewed motion not a new ground; review would undermine Rule 21. Allowed to deny petition; no merit to mandamus relief.
Whether Ex parte Montgomery County Board of Education created a fundamental change in law. Case supports educator immunity; mandates summary judgment. Did not change law; only applied existing standards to facts. No fundamental change; not grounds for relief.

Key Cases Cited

  • Ex parte Cranman, 792 So.2d 392 (Ala. 2000) (state-agent immunity framework for government actors)
  • Ex parte Noland Hosp. Montgomery, LLC, 127 So.3d 1160 (Ala. 2012) (presumptively reasonable time for mandamus petition 42 days)
  • Ex parte Troutman Sanders, LLP, 866 So.2d 547 (Ala. 2003) (petitions for writ review of interlocutory orders; timing rules)
  • Ex parte Montgomery County Board of Education, 88 So.3d 837 (Ala. 2012) (educator immunity under Cranman framework; relied on facts of case)
  • Ex parte Butts, 775 So.2d 173 (Ala. 2000) (adoption of Cranman test by majority")
  • Ex parte Rizk, 791 So.2d 911 (Ala. 2000) (explanation of appellate review standards for immunity claims)
  • Ex parte CTB, Inc., 782 So.2d 188 (Ala. 2000) (affirming judgment on any valid ground presented by the record)
Read the full case

Case Details

Case Name: Hall ex rel. Hall v. Jones
Court Name: Supreme Court of Alabama
Date Published: Dec 20, 2013
Citations: 147 So. 3d 415; 2013 Ala. LEXIS 190; 2013 WL 6703448; 1120950
Docket Number: 1120950
Court Abbreviation: Ala.
Log In
    Hall ex rel. Hall v. Jones, 147 So. 3d 415