TUGGLE v. ROSE Et Al., 333 Ga. App. 362

P. R. was a 7th-grade student in Tuggle's Fulton County language arts class in 2012.
Tuggle allegedly placed P. R. in a headlock, surrounding his neck and guiding him around the room.
The headlock duration is contested; one affidavit claims about 20 minutes, while deposition says P. R. could not gauge time.
P. R. readjusted to his seat and reported neck discomfort after the incident.
Tuggle moved for summary judgment on official immunity, arguing no malice, while the trial court denied it.
The court ultimately held that Tuggle was entitled to official immunity and reversed the trial court's denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Tuggle is entitled to official immunity.	P. R. argues evidence shows malice and intentional harm.	Tuggle asserts no malice and no intent to harm; she held him briefly.	Yes; Tuggle entitled to official immunity; no genuine malice shown.
Whether the duration/evidence of the headlock supports malice.	Evidence of long duration supports an inference of malice.	Duration evidence is inadmissible or insufficient to show malice.	No; duration evidence does not establish malice to defeat immunity.

Griswold v. Collins, 318 Ga. App. 556 (Ga. Ct. App. 2012) (reaffirming high bar for actual malice to overcome immunity)
Butler v. McNeal, 252 Ga. App. 68 (Ga. Ct. App. 2001) (ambiguous classroom conduct not circumstantial evidence of malice)
Murphy v. Bajjani, 282 Ga. 197 (Ga. 2007) (actual malice requires deliberate intention to do wrong)
Prophecy Corp. v. Charles Rossignol, Inc., 256 Ga. 27 (Ga. 1986) (constrains use of self-contradictory testimony on summary judgment)
In the Interest of D. E., 313 Ga. App. 414 (Ga. Ct. App. 2011) (business records hearsay limits; multiple layers of hearsay)