Teplick v. Moulton, 116 So. 3d 1119

Teplick was Chief of Staff at USA Hospitals, with duties largely administrative and no hiring/firing authority, while also holding adjunct or honorary academic titles.
USA eliminated Teplick’s Chief of Staff position in 2009 for financial/organizational reasons; Teplick’s employment ended March 31, 2009.
Teplick argued he had staff-employee or faculty-member status entitling due-process rights, potentially creating a property interest in continued employment.
USA treated Teplick as an at-will administrative employee designated as “110”; he signed a staff handbook receipt but the handbook contemplates staff, not executive/admin roles, and Teplick was not a regular faculty member.
Teplick sought injunctive relief reinstating him as Chief of Staff and damages; defendants moved for summary judgment based on State immunity and Cranman immunity, which the trial court denied and this petition followed.
The Alabama Supreme Court granted mandamus, directing entry of summary judgment for defendants on all claims based on State immunity and State-agent immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether official-capacity claims are barred by State immunity	Teplick seeks reinstatement and may pursue injunctive relief notwithstanding immunity.	§14 immunizes State officers from damages in official capacity; exceptions do not apply here.	Yes; official-capacity claims are barred; mandamus grants summary judgment for defendants.
Whether Teplick had a protected property interest requiring due process	Elimination of the Chief of Staff created a property interest and due process was due.	Employment at will; no guaranteed property interest without a definite term or contract.	No; Teplick had no protected property interest; no due-process duty.
Whether Teplick's fraud claim against Hammack is barred by State-agent immunity	Hammack’s assurances of job security were fraudulent and defeat immunity.	Hammack acted within Cranman’s immunities; no willful, fraudulent conduct shown.	Hammack entitled to State-agent immunity; fraud claim dismissed.
Whether Teplick's ‘malice’ claim against Strada survives immunity	Strada withheld adjunct appointment with malicious intent.	State-agent immunity applies; no evidence of willful misconduct by Strada.	Strada entitled to State-agent immunity; malice claim barred.

Harbert International, Inc. v. Alabama, 990 So.2d 831 (Ala. 2008) (states immunity and exceptions for official-capacity actions)
Drummond Co. v. Alabama Dep’t of Transp., 937 So.2d 56 (Ala. 2006) (exceptions to immunity for certain actions not against the State)
Ex parte Carter, 395 So.2d 65 (Ala. 1980) (original articulation of state-immunity exceptions)
Ex parte Cranman, 792 So.2d 392 (Ala. 2000) (state-agent immunity test for personal capacity claims)
Ex parte Butts, 775 So.2d 173 (Ala. 2000) (limitations on immunity and remedies; aiding framework)
Alabama Agric. & Mech. Univ. v. Jones, 895 So.2d 867 (Ala. 2004) (exceptions to §14 meaning and recoverable relief)
Ex parte Thomas, 110 So.3d 363 (Ala. 2012) (clarifies sixth exception and applicability to damages vs. injunctive relief)
Ex parte Reynolds, 946 So.2d 450 (Ala. 2006) (burden-shifting in State-agent immunity analysis)
Ex parte Kennedy, 992 So.2d 1276 (Ala. 2008) (promissory fraud and state-agent immunity standards)
Patterson v. Gladwin Corp., 835 So.2d 137 (Ala. 2002) (limits to exceptions to immunity; actions against State may still be barred)