No Quasi-Judicial Immunity for Court Case Managers

In December 2013, the plaintiff was arrested for driving under the influence. In July 2014, the plaintiff pled guilty to lesser charges in Atlanta Municipal Court and was sentenced. The matter was then forwarded in error by two of the defendants, case managers employed by the Atlanta Municipal Court, to the State Court of Fulton County for prosecution. The plaintiff’s file, consisting of the bind-over order and related materials, was originally placed in a stack of case files bound over to the state court and intended to be walked over to the state court solicitor's office. After the plaintiff pled guilty, the judge rescinded the bind-over order, but the case managers failed to physically remove the file from the stack. One of the case managers sent an email to the municipal court clerk's office in an effort to stop the file from being forwarded, asking the clerk's office to “[p]lease pull it, and I will be down to retrieve it.” But she did not retrieve the file, and it was forwarded to the state court solicitor for prosecution.

Because the plaintiff was unaware proceedings against him had commenced in state court, he failed to appear for an arraignment hearing. A bench warrant was issued for his arrest, and during a routine traffic stop, he was arrested and spent the night in jail. He was later released, and the state court granted the solicitor's request for an order of nolle prosequi with respect to the charges against him. The plaintiff then sued the Atlanta Municipal Court employees who had allowed his case file to be forwarded in error to the state court, alleging negligence and false arrest, and that case proceeded to trial. At the conclusion of evidence, the trial court granted the defendants’ motion for directed verdict based on their being protected by quasi-judicial immunity. The Court of Appeals agreed, holding that “the trial court correctly concluded that Appellees were acting as [an] ‘extension of the court’ or ‘arm of the judge’ such that they are immune from suit based on quasi-judicial immunity.” The Supreme Court of Georgia granted the plaintiff’s petition for certiorari.

The Supreme Court of Georgia reversed, finding that the defendants’ actions were not protected by quasi-judicial immunity. The Court noted, “the lodestar of judicial and quasi-judicial immunity is whether the actions constitute ‘a function normally performed by a judge.’” The Court found that the task at issue here – removing or failing to remove an order from a stack of case files – is a mere physical task requiring no “discretionary judgment” that is “‘functionally comparable’ to those [made by] judges.” The Court further found that the judicial action occurred much earlier in the chain of events, when the guilty plea was accepted and entered, and the judge's responsibilities concluded. The subsequent steps, such as the removal of the bind-over order, were “administrative ... functions that judges may on occasion be assigned to perform,” which were not judicial in nature.

The defendants also moved for a directed verdict based on official immunity, but the trial court granted a directed verdict solely on the ground of quasi-judicial immunity and did not reach the question of official immunity. The plaintiff argued that the defendants’ acts were ministerial and involved no discretion. But the Court found that whether a public official's acts are ministerial or discretionary is “determined by the facts of each individual case.” The Court remanded the case to the trial court with direction that the trial court must rule in the first instance on the question of whether official immunity applies.

Stanley v. Patterson, 2022 WL 4349306, Civil Action No. S21G0405 (Sept. 20, 2022)