S.K. v. Montgomery County Board of Education, 88 So. 3d 837

S.K., a third-grade student, was injured in a 2007 restroom incident at Peter Crump Elementary after a stall door allegedly jammed.
In 2009, S.K., by her mother, sued the Board, the Board members in their official capacities, and Guice for negligence and wantonness, seeking compensatory and punitive damages.
The Board, Board members, and Guice moved for summary judgment, arguing state immunity, state-agent immunity for Guice, contributory negligence by S.K., and failure to exhaust administrative remedies.
The circuit court denied the motion on July 15, 2011, prompting a mandamus petition to direct entry of summary judgment in the movants' favor.
The Alabama Supreme Court granted the mandamus petition, and issued a writ directing the circuit court to grant summary judgment for the Board, the Board members, and Guice.
The court held that immunity principles under Article I, § 14, Alabama Constitution apply to the Board and its officers, and that Guice qualified for state-agent immunity in her individual capacity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Board has §14 immunity from the tort claims	S.K. argues immunity is not absolute when acts are willful or beyond authority.	Board argues absolute §14 immunity bars tort claims.	Board entitled to §14 immunity; summary judgment in its favor.
Whether Board members and Guice in their official capacities are immune	S.K. argues official-capacity actions indirectly sue the State, defeating immunity.	Officials are immune in official capacities; claims barred.	Board members and Guice in official capacities immune; summary judgment appropriate.
Whether Guice, in her individual capacity, enjoys state-agent immunity	Guice acted within discretion as a teacher; immunity should apply only if not beyond authority.	Guice is entitled to state-agent immunity unless willful/bad-faith beyond authority.	Guice entitled to state-agent immunity; no genuine issue showing willful/bad-faith beyond authority; grant of summary judgment for Guice.

Ex parte Bessemer Bd. of Educ., 68 So.3d 782 (Ala. 2011) (State immunity for a school-board entity)
Ex parte Monroe County Bd. of Educ., 48 So.3d 621 (Ala. 2010) (Immunity framework for county boards of education)
Ex parte Hale County Bd. of Educ., 14 So.3d 844 (Ala. 2009) (Reaffirmed state-immunity for county boards of education)
Ex parte Cranman, 792 So.2d 392 (Ala. 2000) (Adopted burden-shifting test for state-agent immunity)
Ex parte Butts, 775 So.2d 173 (Ala. 2000) (Clarified application of Cranman; majority adopted test)
N.C. v. Caldwell, 77 So.3d 561 (Ala. 2011) (Discussed discretion and authority in assigning student aides)
Ex parte Dangerfield, 49 So.3d 675 (Ala. 2010) (State-officials immune for official-capacity claims; damages bar)