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Keywords

lawsuitplaintiffdefendantnegligenceliabilitymotionsummary judgmentwillbad faithmotion for summary judgment

negligenceliabilitystatutehearingtrialmotionsummary judgmentwillregulationbad faith

Related Cases

Feagins v. Waddy, 978 So.2d 712, 231 Ed. Law Rep. 986

Facts

During the 2002-2003 academic year, Tamesha Feagins, an eighth-grade student at Center Street Middle School, was instructed by her coach, Curtis Waddy, to participate in the high-jump event at a city-wide track meet, despite her lack of experience in that event. Tamesha expressed her concerns about not knowing how to perform a high jump, but Waddy insisted she could do it. While attempting a practice jump, Tamesha injured her knee, which was later diagnosed as a torn ACL requiring surgery. Her mother subsequently filed a lawsuit against Waddy and the athletic director, George Moore, alleging negligence in training and supervision.

Issue

Whether the track coach and athletic director were entitled to State-agent immunity from the negligence claims arising from the student's injury.

Rule

State-agent immunity protects public employees from civil liability when their actions are within the scope of their duties and involve the exercise of judgment. To claim this immunity, the defendants must demonstrate that the claims arise from a function that entitles them to immunity. If they succeed, the burden shifts to the plaintiff to prove that the defendants acted willfully, maliciously, fraudulently, in bad faith, or beyond their authority.

A State agent shall be immune from civil liability in his or her personal capacity when the conduct made the basis of the claim against the agent is based upon the agent's exercising his or her judgment in the administration of a department or agency of government, including, but not limited to, examples such as: … (3) discharging duties imposed on a department or agency by statute, rule, or regulation, insofar as the statute, rule, or regulation prescribes the manner for performing the duties and the State agent performs the duties in that manner; or … (2) when the State agent acts willfully, maliciously, fraudulently, in bad faith, beyond his or her authority, or under a mistaken interpretation of the law.

Analysis

In this case, the court found that Coach Waddy was exercising his judgment in assigning Tamesha to the high-jump event, which falls under the scope of his duties as a coach. The court noted that Waddy's decision was not subject to second-guessing, and there was no evidence presented that he acted outside his authority or failed to follow established rules. The mother's late response to the summary judgment motion was also disregarded, further supporting the court's decision.

In this case, no evidence refuting Waddy and Moore's summary-judgment motion was properly before the trial court. … The record indicates that the trial court instructed Feagins to file a response to the summary-judgment motion on or before May 5, 2006, and that a hearing on the motion was to be held on May 8, 2006. … As was the case in Nall, it is undisputed that Waddy was discharging his duties in educating students by coaching the track team. By selecting which participants would participate in which event, Waddy was exercising his judgment in discharging his duties in educating students, and 'we may not second-guess his decision.'

Conclusion

The court affirmed the summary judgment in favor of Waddy and Moore, concluding that Waddy was entitled to State-agent immunity regarding the negligence claims.

Because the trial court correctly determined that Waddy is entitled to State-agent immunity relating to the decisions he made as a track-and-field coach at a public school, we affirm the summary judgment in his favor.

Who won?

The prevailing party in this case was Curtis Waddy, the track coach, and George Moore, the athletic director. The court ruled in their favor, emphasizing that Waddy's actions were within the scope of his duties and involved the exercise of judgment, which qualified him for State-agent immunity. The court also noted that the mother failed to provide timely evidence to counter the motion for summary judgment, which further solidified the defendants' position.

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