City of Alpharetta v. Bill Vlass

CourtCourt of Appeals of Georgia
DecidedJune 30, 2021
DocketA21A0488
StatusPublished

This text of City of Alpharetta v. Bill Vlass (City of Alpharetta v. Bill Vlass) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Alpharetta v. Bill Vlass, (Ga. Ct. App. 2021).

Opinion

SECOND DIVISION MILLER, P. J., HODGES and PIPKIN, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

DEADLINES ARE NO LONGER TOLLED IN THIS COURT. ALL FILINGS MUST BE SUBMITTED WITHIN THE TIMES SET BY OUR COURT RULES.

June 30, 2021

In the Court of Appeals of Georgia A21A0488, A21A0489. CITY OF ALPHARETTA v. VLASS; and vice versa.

PIPKIN, Judge.

Plaintiff Bill Vlass brought negligence and nuisance claims against the City of

Alpharetta (the “City”) seeking to recover for injuries he received in a motor vehicle

collision. The City moved to dismiss Vlass’ claims based on, inter alia, municipal

immunity; the trial court granted the motion as to Vlass’ negligence claim but denied

the motion as to the nuisance claim.

As set out in the complaint, as amended, on February 15, 2018, Vlass was

driving a school bus northbound on Georgia State Route 9 when a pick-up truck

driven by Charles Wayne Patrick turned left from Devore Road onto State Route 9

into the path of the school bus, causing a “t-bone” collision. Vlass brought a negligence action against the City,1 claiming that the City was negligent because it

failed to prohibit left-hand turns onto State Route 9 from Devore Road despite actual

and/or constructive knowledge of the hazardous condition this created. The City filed

a motion to dismiss, and Vlass amended his complaint to state a nuisance claim on

this same basis; the City then filed a motion to dismiss both claims based on, inter

alia, municipal immunity. On April 8, 2020, the trial court entered an order denying

the City’s motion to dismiss the nuisance claim but granted the motion as to the

negligence claim based on a finding that Vlass had failed to prove the City had

waived its immunity by purchasing insurance. The City filed an application for

interlocutory appeal, which we granted, and that appeal was docketed in this Court

as Case No. A21A0488 (“the nuisance appeal”). Vlass filed a cross appeal from the

dismissal of his negligence claim and that appeal has been docketed in this Court as

Case No. A21A0489 (“the negligence appeal”). As set forth below, we now reverse

in the nuisance appeal and affirm in the negligence appeal.

We first set out the general framework for governmental immunity afforded to

municipalities. “Though originating in the common law, the doctrine of municipal

1 Vlass also sued Patrick, but the parties settled that claim, and Vlass’ complaint was dismissed.

2 immunity now enjoys constitutional status [pursuant to Article IX, Section II,

Paragraph IX of the Georgia Constitution].” Gatto v. City of Statesboro, 2021 GA.

LEXIS 488 at *5 (1) (Case No. S20G0651, decided June 21, 2021). Mayor &

Alderman of the City of Savannah v. Herrera, 343 Ga. App. 424, 427 (1) (808 SE2d

416) (2017); see also CSX Transp., Inc. v. City of Garden City, 277 Ga. 248, 249 (1)

(588 SE2d 688 (2003). That immunity, which under the current version of our

constitution may be waived only by the General Assembly, Gatto, 2021 GA. LEXIS

488 at *5 (1), is codified in OCGA § 36-33-1, which also sets out two narrow

waivers. Pursuant to subsection (a) “[a] municipal corporation shall not waive its

immunity by the purchase of liability insurance . . . unless the policy of insurance

issued covers an occurrence for which the defense of sovereign immunity is available,

and then only to the limits of such insurance policy.” Subsection (b) carves out

another narrow waiver: “[m]unicipal corporations shall not be liable for failure to

perform or for errors in performing their legislative or judicial powers. For neglect

to perform or improper or unskillful performance of their ministerial duties, they shall

be liable.” OCGA § 36-33-1 (b). This latter waiver “has been consistently

‘[i]nterpreted to mean that municipal corporations are immune from liability for acts

taken in performance of a governmental function but may be liable for negligent

3 performance of their ministerial duties.’ City of Atlanta v. Mitcham, 296 Ga. 576,

577-578 (1) (769 SE2d 320) (2015).” Gatto v. City of Statesboro, 353 Ga. App. 178,

181-182 (1) (834 SE2d 623) (2019). Lastly, and importantly, municipal immunity is

not in the nature of an affirmative defense but rather speaks to the trial court’s subject

matter jurisdiction. City of Tybee Island v. Harrod, 337 Ga. App. 523, 524 (788 SE2d

122) (2016). Thus, the burden is on the plaintiff to establish a waiver of immunity.

Id.

CASE NO. A21A0488.

1. With this general framework in mind, we turn first to the trial court’s denial

of the City’s motion to dismiss Vlass’ nuisance claim. In Gatto, 2021 GA. LEXIS

488, our Supreme Court recently set out the “contours” of municipal immunity in

cases involving a nuisance claim. Id. at *1. After first tracing the history of municipal

immunity, the Court observed “[e]ven in the exercise of its governmental functions,

a municipality does not enjoy immunity for all liability.” Id. at *7 (2). The Court went

on to explain,

although protected from liability from negligence actions, a municipality, like any other individual or private corporation, may be liable for damages it causes to a thirty party from the operation or maintenance of a nuisance, irrespective of whether it is exercising a

4 governmental or ministerial function. This exception to sovereign immunity is based on the principle that a municipal corporation can not, under the guise of performing a governmental function, create a nuisance dangerous to life and health or take or damage private property for public purpose, without just and adequate compensation being first paid.

(Punctuation and indention omitted.) Id., quoting City of Thomasville v. Shank, 263

Ga. 624, 624-625 (1) (437 SE2d 306) (1993). As the Court further explained,

though denominated an ‘exception,’ to sovereign immunity in Shank and some other cases, the principle that municipalities may be liable for creating or maintaining a nuisance is actually not an exception at all, but instead, a proper recognition that the Constitution itself requires just compensation for takings and cannot, therefore, be understood to afford immunity for such conduct.’ Georgia Dept. of Nat. Resources v. Center for a Sustainable Coast, Inc., 294 Ga. 593, 600 (2) (755 SE2d 184) (2014).

Gatto, 2021 GA. LEXIS 488 at *7-8 (2). The Court reasoned that, viewed in this

light, “the moniker ‘nuisance exception’ is a misnomer, and it is more apt to refer to

the ‘nuisance doctrine’ when evaluating whether municipal liability may be imposed

in a given case.” Id.

5 The Court next turned to the application of the nuisance doctrine, recognizing,

as it had before, “the challenge is determining what conduct or act on the part of the

municipality will result in the creation or maintenance of a nuisance, as opposed to

an action in negligence.” (Punctuation omitted.) Id. at *8, quoting Hibbs v. City of

Riverdale, 267 Ga. 337, 338 (478 SE2d 121) (1996). Not surprisingly, given that the

roots of the nuisance doctrine extend squarely into the Takings Clause of our State

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