Carol Rogers, as administratrix of the Estate of Susan Bonner v. Cedar Bluff Volunteer Fire Department

CourtSupreme Court of Alabama
DecidedAugust 29, 2025
DocketSC-2025-0055
StatusPublished

This text of Carol Rogers, as administratrix of the Estate of Susan Bonner v. Cedar Bluff Volunteer Fire Department (Carol Rogers, as administratrix of the Estate of Susan Bonner v. Cedar Bluff Volunteer Fire Department) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carol Rogers, as administratrix of the Estate of Susan Bonner v. Cedar Bluff Volunteer Fire Department, (Ala. 2025).

Opinion

Rel: August 29, 2025

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is printed in Southern Reporter.

SUPREME COURT OF ALABAMA SPECIAL TERM, 2025

_________________________

SC-2025-0055 _________________________

Carol Rogers, as administratrix of the Estate of Susan Bonner, deceased

v.

Cedar Bluff Volunteer Fire Department

Appeal from Cherokee Circuit Court (CV-2019-900085)

COOK, Justice.

This is a tragic case involving the death of an automobile-accident SC-2025-0055

victim and how Alabama's Volunteer Service Act ("the VSA"), § 6-5-336,

Ala. Code 1975, applies. 1 Given the Legislature's decision to provide

immunity to volunteers under certain circumstances through the VSA,

the question to be resolved in this appeal is whether a municipality that

has a volunteer fire department can be held vicariously liable for the acts

or omissions of a volunteer firefighter.

Carol Rogers, the administratrix of the estate of Susan Bonner,

deceased, sued, among others, the Cedar Bluff Volunteer Fire

Department ("the CBVFD"), which is a subordinate entity of the Town of

Cedar Bluff ("the Town"), 2 and Howard Guice, a former volunteer

firefighter and emergency medical technician with the CBVFD, after

Bonner was killed in an automobile accident. Guice responded to the

accident scene but purportedly negligently contributed to Bonner's death.

The Town moved for a summary judgment on the basis that the

CBVFD was one of its subordinate entities and, assuming that he had

1The VSA is informally known as the "Good Samaritan Act."

2Rogers's complaint actually listed only the CBVFD, not the Town,

as a defendant. However, as explained in more detail below, because the CBVFD is a subordinate entity of the Town, any arguments that Rogers raises in connection with the CBVFD are, in fact, directed toward the Town. 2 SC-2025-0055

responded to the accident scene in his capacity as a volunteer firefighter

with the CBVFD, Guice was immune from liability under the VSA. As a

result, the Town argued that it, too, was immune from liability.

The Cherokee Circuit Court found that, under our Court's prior

decision in Hollis v. City of Brighton, 885 So. 2d 135 (Ala. 2004), the

CBVFD "is a political subdivision of [the Town] and does not exist

separate and apart from [the Town]" and, therefore, that the Town is

"immune from liability for the negligence of" its volunteer firefighters,

including Guice. It thus entered a summary judgment in favor of the

Town. Rogers appealed.

For the reasons explained below, we conclude that, under Hollis,

that judgment was proper and is therefore due to be affirmed.

Facts and Procedural History

I. The Underlying Accident

On June 6, 2017, Bonner was driving on County Road 45 in

Cherokee County when her vehicle left the roadway and ended up

submerged in a creek. After Bonner was rescued by passing motorists, a

bystander who also happened to be a volunteer firefighter with the

McCord's Crossroads Volunteer Fire Department ("the MCVFD") began

3 SC-2025-0055

performing cardiopulmonary resuscitation ("CPR") on Bonner. At some

point thereafter, Cherokee County Emergency Medical Services

("Cherokee County EMS") was notified of the accident, and paramedics

were dispatched to the scene.

Guice was nearby, allegedly on a personal errand, and heard the

call about the accident on a radio issued to him by the CBVFD.3 Even

though the scene was not within the CBVFD's service area and even

though the CBVFD had not dispatched him to the scene, Guice decided

to go to the scene to see if he could assist the paramedics. After Guice

arrived, the bystander who had been performing CPR on Bonner asked

Guice to take over, but Guice declined. Instead, he advised that all

resuscitative efforts should cease and stated over his CBVFD-issued

radio that a death had occurred at the scene. Guice then allegedly

entered the water to help other bystanders search for a possible second

victim in Bonner's submerged vehicle.

Five minutes after the bystander ceased performing CPR on

Bonner, Cherokee County EMS paramedics arrived at the scene. They

3That radio gave Guice access to radio frequencies reserved for use

by emergency medical personnel and firefighters.

4 SC-2025-0055

examined Bonner and found that she was warm to the touch, had a pulse,

and had responsive pupils. As a result, the paramedics performed CPR

on her until she experienced a return of spontaneous circulation. Bonner

was transported to the hospital for further treatment but died two days

later as a result of anoxic encephalopathy.4

II. Rogers's Lawsuit

After Rogers was appointed as the administratrix of Bonner's

estate, she commenced the present wrongful-death action against Guice

and numerous fictitiously named defendants, alleging various theories of

liability.5 Rogers later filed an amended complaint substituting the

CBVFD and the Cherokee County Association of Volunteer Fire

Departments, Inc. ("the Association"), for the fictitiously named

defendants.

After the defendants filed their respective answers, Rogers filed a

second amended complaint in which she "consolidated all claims under

4According to the record, anoxic encephalopathy occurs when blood

ceases to flow to the brain.

5Rogers initially sued the MCVFD; however, the parties later moved to dismiss the MCVFD from her action, and the trial court granted that request.

5 SC-2025-0055

one claim for wrongful death" against the CBVFD, the Association, and

Guice. In her second amended complaint, Rogers alleged that Guice's

response to Bonner's accident was deficient and that, because Guice had

responded to the scene in his capacity as a volunteer firefighter, his

actions or omissions were attributable to both the CBVFD and the

Association. Therefore, Rogers alleged, the CBVFD and the Association

were vicariously liable for Guice's negligence and/or wantonness.

In response, the Town6 filed a motion for partial dismissal of

Rogers's second amended complaint, in which it argued that Rogers's

claims against it were not cognizable because, among other reasons, it

was not only immune from liability in general, but was also immune from

6As noted above, Rogers originally sought to substitute or add the

CBVFD, not the Town, as a defendant in its amended complaint. However, early in this litigation, the Town maintained that, because the CBVFD was its volunteer fire department and was not a separate legal entity, the CBVFD was not a suable entity. As a result, the Town consistently referred to itself in place of the CBVFD in its filings below. However, nothing in the record indicates that the Town ever took any formal steps in the trial court to substitute itself for the CBVFD or to otherwise correct the style of the case.

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Carol Rogers, as administratrix of the Estate of Susan Bonner v. Cedar Bluff Volunteer Fire Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carol-rogers-as-administratrix-of-the-estate-of-susan-bonner-v-cedar-ala-2025.