Smith v. Daniel (Majority, with Concurring and Dissenting)
Annotate this CaseGloria Daniel was fired from her position as a registered nurse at the Arkansas State Hospital thirteen months after she reported to Charles Smith, the hospital’s administrator, that a patient’s death was attributable to abuse or neglect on the part of the hospital. Daniel filed suit, asserting claims under the Arkansas Whistle-Blower Act, the Arkansas Civil Rights Act, and federal law, naming as Defendants Smith in his individual and official capacities, and Betty Mains in her official and individual capacities as the hospital’s assistant administrator. The circuit court concluded that Daniel’s claim for retaliation was not barred by sovereign immunity and that Defendants were not entitled to qualified immunity. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the circuit court (1) did not err in denying Defendants’ motion for summary judgment based on sovereign immunity; and (2) erred in denying Defendants’ motion for summary judgment to dismiss the individual-capacity claims based on qualified statutory immunity grounds.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.