PUBLIC EMPLOYMENT - ALABAMA

Woodfin v. Bender

Supreme Court of Alabama - March 31, 2017 - So.3d - 2017 WL 1192891

Classified employees of city board of education brought action against board, its members in their official capacities, and school district superintendent in his official capacity for declaratory, mandamus, and injunctive relief, claiming that employees had not been reassigned to proper “steps” on newly-adopted salary schedule and thus that their wages were miscalculated.

The Circuit Court dismissed board from the case on the basis of sovereign immunity, but, following bench trial, entered judgment against board members and superintendent. Board members and superintendent appealed.

The Supreme Court of Alabama held that implementation of schedule involved discretion such that board members and superintendent had state sovereign immunity from employees’ action.

Members of city board of education, in their official capacities, and superintendent, in his official capacity, did not exceed their discretion or act arbitrarily when they interpreted and implemented school board’s new salary schedule policy, which stated that “Years of experience are categorized as ‘STEPS’ on the schedule,” by initially placing existing classified employees to steps on the new salary schedule that directly corresponded to their then current rate of pay rather than their years of service, and thus board members and superintendent had state sovereign immunity from employees’ action for mandamus and injunctive relief claiming salary miscalculation.



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