From Casetext: Smarter Legal Research

Alexander v. Hatfield

Supreme Court of Alabama
Jan 13, 1995
652 So. 2d 1142 (Ala. 1995)

Summary

holding that deputy sheriff was immune from suit claiming negligence in the performance of his statutory duties

Summary of this case from Lancaster v. Monroe County

Opinion

1930950.

November 4, 1994. Rehearing Denied January 13, 1995.

Appeal from the Montgomery Circuit Court, No. CV-92-103, Joseph D. Phelps, J.

Allen R. Stoner of McPhillips, Shinbaum Gill, Montgomery, for appellant.

Thomas T. Gallion III of Haskell, Slaughter, Young, Johnston Gallion, Montgomery, for appellee.


Otis Alexander sued Betty Hatfield, a deputy sheriff, individually and in her official capacity as a deputy sheriff, alleging negligent and/or bad faith service of process. The trial court entered a summary judgment in favor of Deputy Hatfield. Alexander appealed.

Alexander was the respondent in regard to a petition for a rule nisi filed in Autauga County, Alabama, by his ex-wife. Unable to serve Alexander at his residence in Autauga County, the Autauga sheriff referred the process to the Montgomery County Sheriffs Office for delivery to Alexander at his place of employment in Montgomery County, Rheem Manufacturing Company.

Deputy Hatfield, a sergeant with the Montgomery County Sheriffs Office, has been serving papers at Rheem for over 14 years. At Rheem's request, service of process was completed on employees by leaving the papers with the personnel manager, who would then serve the employee. Rheem followed this practice so that its employees would not lose production time or be embarrassed by having papers served on them while they were working.

Alexander denies receiving the papers at Rheem. He was arrested and was incarcerated for six days because he failed to appear at the rule nisi hearing. Alexander sued Deputy Hatfield for negligent and/or bad faith service of process.

We must first consider whether Deputy Hatfield, individually and in her official capacity, is immune from suit. If she is, then the judgment for her was proper.

A sheriff is an employee of the State and, as such, is immune from suit, in his official capacity, for negligent performance of his statutory duties. Parker v. Amerson, 519 So.2d 442 (Ala. 1987); see also Wright v. Bailey, 611 So.2d 300 (Ala. 1992). State officers and employees, in their official capacities and individually, also are absolutely immune from suit when the action is, in effect, one against the State. Phillips v. Thomas, 555 So.2d 81 (Ala. 1989).

Under Article I, § 14, of the Alabama Constitution of 1901, the only exceptions to the sovereign immunity of sheriffs are actions brought

"(1) to compel him to perform his duties, (2) to compel him to perform ministerial acts, (3) to enjoin him from enforcing unconstitutional laws, (4) to enjoin him from acting in bad faith, fraudulently, beyond his authority, or under mistaken interpretation of the law, or (5) to seek construction of a statute under the Declaratory Judgment Act if he is a necessary party for the construction of the statute."

Parker v. Amerson, 519 So.2d 442, at 443 (Ala. 1987).

We have also held that deputy sheriffs are immune from suit to the same extent as sheriffs. "In general, the acts of the deputy sheriff are the acts of the sheriff. The deputy sheriff is the alter ego of the sheriff." Carr v. City of Florence, Alabama, 916 F.2d 1521, 1526 (11th Cir. 1990), quoted with approval in Drain v. Odom, 631 So.2d 971, 972 (Ala. 1994), and Wright v. Bailey, 611 So.2d 300, 303 (Ala. 1992). "[Under Alabama law, a] deputy is legally an extension of the sheriff. If the deputy's acts are generally considered the acts of the sheriff, it is logical that those acts should enjoy the same immunity covering the sheriffs own acts." Carr, at 1526, quoted with approval in Wright v. Bailey, at 303.

In this case, none of the exceptions set out in Parker v. Amerson applies. Deputy Hatfield was on duty when she left the papers at Alexander's place of employment. Therefore, the summary judgment in favor of Deputy Hatfield, individually and in her official capacity, was proper, based on the sovereign immunity granted under Article I, § 14, of the Alabama Constitution of 1901.

AFFIRMED.

MADDOX, SHORES, HOUSTON and STEAGALL, JJ., concur.


Summaries of

Alexander v. Hatfield

Supreme Court of Alabama
Jan 13, 1995
652 So. 2d 1142 (Ala. 1995)

holding that deputy sheriff was immune from suit claiming negligence in the performance of his statutory duties

Summary of this case from Lancaster v. Monroe County

holding that a deputy sheriff was entitled to absolute immunity from a claim for "bad faith" service of process

Summary of this case from Horton v. Morgan Cnty. Sheriff's Dep't

holding that deputies have the same immunity as sheriffs because a deputy is but a legal extension of the sheriff — his acts are the acts of the sheriff

Summary of this case from Vinson v. Clarke County, Ala.

In Alexander v. Hatfield, 652 So.2d 1142, 1143 (Ala. 1994), the plaintiff sued the sheriff for negligence and bad faith service of process.

Summary of this case from Tinney v. Shores

explaining that "state officers and employees, in their official capacities . . . are absolutely immune from suit when the action is, in effect, one against the State"

Summary of this case from T.R. v. Lamar Cnty. Bd. of Educ.

providing exceptions to State immunity enjoyed by sheriffs and deputy sheriffs for equitable-relief claims

Summary of this case from Gaines v. Smith

restating the principle that " ‘[t]he deputy sheriff is the alter ego of the sheriff’ " and that a " ‘deputy is legally an extension of the sheriff’ " (quoting Carr v. City of Florence, 916 F.2d 1521, 1526 (11th Cir. 1990))

Summary of this case from Gaines v. Smith

noting situations in which § 14 does not shield sheriffs from an action brought against them in either their official or individual capacities

Summary of this case from Suttles v. Roy

In Alexander v. Hatfield, 652 So.2d 1142 (Ala. 1994), this Court held that a deputy sheriff is afforded the same immunity from suit as a sheriff in regard to claims for monetary damages stemming from activities performed while working in the line and scope of his or her employment.

Summary of this case from Ex Parte Purvis

In Alexander v. Hatfield, 652 So.2d 1142, 1143 (Ala. 1994), the plaintiff sued the sheriff for negligence and bad faith service of process.

Summary of this case from Ex Parte Purvis

In Alexander, a deputy sheriff, Betty Hatfield, was sued individually and in her capacity as a deputy sheriff on claims of negligence and/or bad faith service of process.

Summary of this case from Karrick v. Johnson
Case details for

Alexander v. Hatfield

Case Details

Full title:Otis ALEXANDER v. B. HATFIELD, Individually and in Her Official Capacity…

Court:Supreme Court of Alabama

Date published: Jan 13, 1995

Citations

652 So. 2d 1142 (Ala. 1995)

Citing Cases

McMillian v. Johnson

Gill v. Sewell, 356 So.2d 1196, 1198 (Ala. 1978) ("This list was never intended to be a comprehensive final…

Ex Parte Purvis

In Karrick, this Court reiterated the limited circumstances in which a sheriff and a sheriffs deputy are…