Ex parte State of Alabama Board of Education et al.Annotate this Case
The State of Alabama Board of Education ("SBOE") and several of its executive directors petitioned the Supreme Court for a writ of mandamus to direct the Jefferson Circuit Court to vacate its order denying their motion to dismiss claims filed against them by respondent Sharper Adams and numerous employees of the Birmingham Board of Education (BBOE). Petitioners sought to have all claims dismissed with prejudice on immunity grounds. The BBOE failed to submit a financial-recovery plan to the SBOE by an April 2, 2012, deadline, and its minimum-reserve fund remained underfunded. Once complete, the financial-recovery plan included, among other things, a reduction in force ("RIF"), which required that the jobs of the respondents, among others, be eliminated. The circuit court determined that petitioners had violated the respondents' federal due-process rights by depriving them of their property interest without due process of law because, the circuit court concluded, the petitioners failed to comply with the procedural requirements of the Students First Act ("the SFA"). Specifically, the circuit court concluded that the SFA, a state law, required that the respondents receive notice of the fact that the implementation of the RIF would result in the termination of their employment positions with the BBOE and that the petitioners failed to give the respondents such notice. Accordingly, the circuit court concluded that the respondents' federal due-process rights had been violated. After review, the Supreme Court granted petitioners' petition in part, and denied it in part. The Court granted the petition with regard to claims against the individual administrators in their official capacities, finding they were entitled to immunity. The Court denied the petition with regard to claims agains the SBOE.