STANLEY v. PATTERSON, 314 Ga. 582

In Dec. 2013 Appellant was arrested for DUI and prosecuted in Atlanta Municipal Court; after a guilty plea the judge rescinded a prior bind‑over order.
Two Atlanta Municipal Court case managers failed to remove Appellant’s bind‑over order from a physical stack of files destined for the State Court solicitor, so the file was forwarded in error.
Appellant received no notice of state‑court proceedings, failed to appear at arraignment, and a bench warrant issued; he was later arrested and jailed overnight.
Appellant sued the municipal court employees for negligence (he withdrew a false‑arrest claim at trial).
The trial court granted a directed verdict for Appellees based on quasi‑judicial immunity; the Court of Appeals affirmed. The Georgia Supreme Court granted certiorari.
The Supreme Court reversed the Court of Appeals, holding quasi‑judicial immunity did not apply and remanding for the trial court to decide official immunity (ministerial vs. discretionary) in the first instance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Appellees are protected by quasi‑judicial immunity for failing to remove the bind‑over order	Stanley: failure to remove was a routine, nonjudicial/ministerial act — not protected	Appellees: acted as an "extension of the court" (relying on Withers) and thus are quasi‑judicially immune	No — removing a paper order is a nonjudicial, purely administrative/physical task; immunity does not apply
Whether Withers v. Schroeder controls	Stanley: Withers is distinguishable — that involved a statutorily assigned court duty and judicial determination	Appellees: Withers shows court staff can be immune when performing tasks at a judge's direction	Withers is limited to its facts; immunity in Withers rested on a court‑assigned judicial function, not mere association with a judge
Whether official (qualified) immunity bars liability (directed verdict)	Stanley: acts were ministerial and thus potentially subject to liability	Appellees: asserted official immunity as alternative ground	Not decided on the merits — trial court must address official immunity on remand (ministerial vs. discretionary question unresolved)

Heiskell v. Roberts, 295 Ga. 795 (quasi‑judicial immunity applies only to functions normally performed by a judge)
Withers v. Schroeder, 304 Ga. 394 (court administrator held immune where performing a statutory court function involving judicial determination)
Mireles v. Waco, 502 U.S. 9 (judicial immunity protects acts within judicial jurisdiction)
Forrester v. White, 484 U.S. 219 (distinguishes judicial from administrative/nonjudicial functions)
Antoine v. Byers & Anderson, Inc., 508 U.S. 429 (quasi‑judicial immunity for nonjudges performing functions comparable to judges)
Pierson v. Ray, 386 U.S. 547 (historical common‑law basis for judicial immunity)
Arthur Andersen & Co. v. Wilson, 256 Ga. 849 (nonjudicial actors can be cloaked in judicial immunity when performing court‑authorized judicial acts)
Gilbert v. Richardson, 264 Ga. 744 (Georgia official immunity framework: ministerial acts vs. discretionary acts)
Hicks v. McGee, 289 Ga. 573 (defining ministerial and discretionary acts for official immunity analysis)