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Hereford v. Jefferson County

Supreme Court of Alabama
Aug 23, 1991
586 So. 2d 209 (Ala. 1991)

Summary

holding that a deputy sheriff, as a legal extension of the sheriff, was entitled to the same immunity as the sheriff acting on behalf of the State

Summary of this case from Junkins v. Glencoe Volunteer Fire Dept

Opinion

1900708.

August 23, 1991.

Appeal from the Circuit Court, Jefferson County, No. CV-86-5789, Arthur J. Hanes, Jr., J.

Alicia K. Haynes, Birmingham, for appellants.

Charles S. Wagner, Asst. County Atty., Birmingham, for appellee Jefferson County.

J. Fred Wood, Jr. and Terry McElheny of Dominick, Fletcher, Yeilding, Wood Lloyd, P.A., Birmingham, for appellees Walter Brandon and Al Finley.


On September 15, 1985, William Blevins, a prisoner in the Jefferson County jail serving a sentence of life without parole, was mistakenly released instead of William Blevins McCrary, also a prisoner at the jail, who was to have been released pursuant to a suspension of his sentence. On October 14, 1985, Blevins robbed George Hereford and Terry Parks at the Quality Auto Parts store, which they own and operate. Blevins was later arrested and convicted of the robbery.

Hereford and Parks sued Jefferson County; Melvin Bailey, individually and in his capacity as sheriff of Jefferson County; Deputy Ernest Poelnitz; Deputy Walter Brandon; Deputy Al Finley; and Deputy Deidre Poole, alleging negligence and wantonness in releasing Blevins. The trial court entered a summary judgment for Poelnitz, to which the plaintiffs consented, and, on Poole's motion, severed the claim against her. On August 21, 1990, the trial court entered a summary judgment for all of the remaining defendants. Hereford and Parks appeal.

Our first inquiry is whether the defendants are immune from suit. If they are, then the judgment for them was proper. In Parker v. Amerson, 519 So.2d 442 (Ala. 1987), the Eleventh Circuit Court of Appeals asked this Court to decide whether a sheriff is an employee of a county for purposes of holding the county vicariously liable. We held that a sheriff is an employee of the state, rather than a county, based on the following constitutional provision: "The executive department shall consist of a governor . . . and a sheriff for each county." Article V, § 112, Alabama Constitution of 1901. As executive officers, sheriffs have sovereign immunity under Article I, § 14, of the Alabama Constitution, which reads: "[T]he State of Alabama shall never be made a defendant in any court of law or equity." The only exceptions to such immunity are for actions brought against a sheriff:

"(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."

519 So.2d at 443. None of those exceptions applies here.

We also held in Parker v. Amerson, supra, that Ala. Code 1975, § 14-6-1, which made a sheriff civilly liable for the acts of his jailer, was unconstitutional as being in derogation of Article I, § 14, of the Alabama Constitution. Applying the holdings of that case to the instant case, we are compelled to conclude that Sheriff Bailey, as an executive officer of the State of Alabama, has sovereign immunity under § 14; thus, Jefferson County cannot be vicariously liable. See, also, Oliver v. Townsend, 534 So.2d 1038 (Ala. 1988).

We must reach the same conclusion with regard to Deputies Brandon and Finley. In Mosely v. Kennedy, 245 Ala. 448, 450, 17 So.2d 536, 537 (1944), this Court stated, "In general, the acts of the deputy sheriff are the acts of the sheriff. The deputy sheriff is the alter ego of the sheriff." (Citations omitted.) In dealing with the same issue that is present here, the federal appellate court in Carr v. City of Florence, Alabama, 916 F.2d 1521, 1526 (11th Cir. 1990), affirmed summary judgments for the Lauderdale County sheriff and his deputies, stating:

"[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 also enjoy the immunity covering the sheriff's own acts."

We hold, therefore, that the summary judgments for defendants Jefferson County, Sheriff Bailey, and Deputies Brandon and Finley were correct and are due to be affirmed.

AFFIRMED.

HORNSBY, C.J., and SHORES, ADAMS and INGRAM, JJ., concur.


Summaries of

Hereford v. Jefferson County

Supreme Court of Alabama
Aug 23, 1991
586 So. 2d 209 (Ala. 1991)

holding that a deputy sheriff, as a legal extension of the sheriff, was entitled to the same immunity as the sheriff acting on behalf of the State

Summary of this case from Junkins v. Glencoe Volunteer Fire Dept

finding that sheriffs are executive officers of the state based on constitutional provision and, accordingly, are immune from suit

Summary of this case from R.A. v. Deputy Sheriff Walter Lacey

In Hereford v. Jefferson County, 586 So.2d 209 (Ala. 1991), the Alabama Supreme Court held that deputy sheriffs are immune from suit to the same extent as sheriffs because "the deputy sheriff is the alter ego of the sheriff."

Summary of this case from Young v. Myhrer

In Hereford, a plaintiff sued a sheriff and four deputies for negligence and wantonness, claiming they wrongfully released an inmate who was serving a life sentence without the possibility of parole.

Summary of this case from King v. Moon

In Hereford, sheriff's deputies mistakenly released the wrong prisoner, more dangerous than the prisoner authorized to be released, with the result that plaintiffs were robbed.

Summary of this case from Williams v. Goldsmith

dealing with liability of sheriff in his official and individual capacities for negligently or wantonly releasing a dangerous prisoner

Summary of this case from McMillian v. Johnson

In Hereford v. Jefferson County, 586 So.2d 209 (Ala. 1991), we held that deputy sheriffs are immune from suit to the same extent as sheriffs.

Summary of this case from Wright v. Bailey

In Hereford, we relied upon Mosely v. Kennedy, 245 Ala. 448, 450, 17 So.2d 536, 537 (1944), stating: "In general, the acts of the deputy sheriff are the acts of the sheriff.

Summary of this case from Wright v. Bailey
Case details for

Hereford v. Jefferson County

Case Details

Full title:George L. HEREFORD and Terry Lynn Parks v. JEFFERSON COUNTY, et al

Court:Supreme Court of Alabama

Date published: Aug 23, 1991

Citations

586 So. 2d 209 (Ala. 1991)

Citing Cases

R.A. v. Deputy Sheriff Walter Lacey

The deputy sheriff is the alter ego of the sheriff." Hereford v. Jefferson County, 586 So. 2d 209, 210 (Ala.…

Williams v. Goldsmith

The rule is more easily stated than applied. The facts of Hereford v. Jefferson County, 586 So.2d 209 (Ala.…