Robinson v. Montgomery County Board of Education

CourtDistrict Court, M.D. Alabama
DecidedJuly 28, 2021
Docket2:15-cv-00924
StatusUnknown

This text of Robinson v. Montgomery County Board of Education (Robinson v. Montgomery County Board of Education) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robinson v. Montgomery County Board of Education, (M.D. Ala. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

KYRA ROBINSON, ) ) Plaintiff, ) ) v. ) CASE NO. 2:15-CV-924-WKW ) [WO] MONTGOMERY COUNTY ) BOARD OF EDUCATION, et al., ) ) Defendants. )

MEMORANDUM OPINION AND ORDER On November 18, 2020, Kyra Robinson (“Robinson”) filed a third amended complaint against Defendants Tramene Maye (“Maye”), Rafiq Vaughn (“Vaughn”), and the Montgomery County Board of Education (the “Board”). (Doc. # 69.) Robinson brings three counts in her complaint: (1) a Title IX claim against the Board; (2) a state-law negligence/wantonness claim against Maye in his individual capacity; and (3) a state-law intentional infliction of emotional distress (“outrage”) claim against Vaughn in his individual capacity.1 The Board has answered Robinson’s complaint. (Doc. # 70.) Before the court is Maye’s and Vaughn’s Motion to Dismiss (Doc. # 79), which is fully briefed (Docs. # 80, 83, 85). In their

1 Robinson has voluntarily dismissed her official capacity claims against Maye and Vaughn. (See Doc. # 83, at 5 (explaining that she has “voluntarily dismiss[ed] the [§] 1983 claims brought against Vaughn and Maye in their officials capacities, leaving only the state law claims against them in their individual capacities . . .”).) motion, Maye and Vaughn only seek to dismiss Robinson’s state-law claims. After careful consideration of the arguments of counsel, the applicable law, and the facts,

the court finds that the motion to dismiss is due to be granted in part and denied in part. I. JURISDICTION AND VENUE

The court exercises subject matter jurisdiction over Robinson’s Title IX claim pursuant to 28 U.S.C. §§ 1331 (federal question), 1343 (civil rights jurisdiction), and supplemental jurisdiction over the state-law claims under 28 U.S.C. § 1367. Personal jurisdiction and venue are not contested.

II. STANDARD OF REVIEW When evaluating a motion to dismiss pursuant to Rule 12(b)(6), the court must take the facts alleged in the complaint as true and construe them in the light most

favorable to the plaintiff. Resnick v. AvMed, Inc., 693 F.3d 1317, 1321–22 (11th Cir. 2012). To survive Rule 12(b)(6) scrutiny, “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v.

Twombly, 550 U.S. 544, 570 (2007)). “[F]acial plausibility” exists “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. (citation omitted). The well-pleaded factual allegations in the complaint, but not its legal conclusions, are presumed true. Id. (citation omitted).

III. BACKGROUND Because this opinion assumes the parties’ familiarity with the procedural history and record, the court will only briefly outline the facts underlying Robinson’s

state-law claims against Maye and Vaughn. On October 24, 2014, Robinson (then a student at Southlawn Middle School) “was walking off of the Southlawn Middle School campus at the end of the school day when a group of three boys grabbed her and dragged her into an abandoned building on the perimeter of the school property.”

Robinson’s stepsister, who had been walking with her at the time, informed Maye (then assistant principal of Southlawn Middle School) of what had just happened. Maye did not take any action, instead telling Robinson’s stepsister to “go on about

her business.” According to Robinson, Maye witnessed the three boys grabbing and dragging her into the abandoned building. In the abandoned building, two of the boys gang raped Robinson while the third kept a lookout. (Doc. # 69, at 7–8.) Robinson’s mother, who happened to be on Southlawn’s campus that day

attending a parent teacher conference, soon learned of her daughter’s rape. She, along with Robinson, immediately went to discuss it with Vaughn (then principal of Southlawn Middle School). During the meeting, Vaughn showed “little concern for

Robinson.” He pleaded with Robinson’s mother not to call the media. To make matters worse, Vaughn told Robinson that “she needed to love her body,” and he remarked that Robinson had an adult figure like his girlfriend’s. (Doc. # 69, at 8–

9.) Maye and Vaughn make three arguments in support of their motion to dismiss. First, they contend that the doctrine of State absolute immunity bars Robinson’s

state-law claims against them in their individual capacities. Second, they assert that they are entitled to state-agent immunity on those same claims. Third, and finally, Maye and Vaughn argue that Robinson’s state-law claims against them fail on the merits. Each issue will be addressed in turn.

IV. DISCUSSION A. State absolute immunity does not apply. Article I, § 14 of the Alabama Constitution provides that “the State of

Alabama shall never be made a defendant in any court of law or equity.” This constitutional provision creates a “nearly impregnable and almost invincible wall that provides the State an unwaivable, absolute immunity from suit . . . in any court.” Ex parte Town of Lowndesboro, 950 So. 2d 1203, 1206 (Ala. 2006) (citations and

quotations omitted). The Alabama Supreme Court “has noted the general rule that the State immunity provided by § 14 ‘cannot be circumvented by suing the [State] official or agent individually . . . .’” Barnhart v. Ingalls, 275 So. 3d 1112, 1125 (Ala.

2018) (quoting Milton v. Espey, 356 So. 2d 1201, 1202 (Ala. 1978)) (alteration in original). This general rule, however, is not without exceptions: State absolute immunity does not apply to “‘actions for damages brought against State officials in

their individual capacity where it is alleged that they acted fraudulently, in bad faith, beyond their authority, or in a mistaken interpretation of law, subject to the limitation that the action not be, in effect, one against the State.’” Id. (quoting Ex parte

Moulton, 116 So. 3d 1119, 1141 (Ala. 2013)). To determine “whether an action against a state officer or employee is, in fact, one against the State, a court will consider such factors as the nature of the action and the relief sought.” Haley v. Barbour Cnty., 885 So. 2d 783, 788 (Ala. 2004) (cleaned up).

Here, Maye and Vaughn assert that the nature of Robinson’s action against them transforms her individual-capacity claims into an action against the State; hence, such claims are barred by State absolute immunity. (See Doc. # 80, at 6.) To

support their position, Maye and Vaughn rely on the Alabama Supreme Court’s Barnhart decision. For the reasons to follow, State absolute immunity bars neither Robinson’s negligence/wantonness claim against Maye nor her outrage claim against Vaughn.

In Barnhart, the plaintiffs—former employees of the Space Science Exhibit Commission—brought a putative class action against the Commission’s officers alleging, among other things, “negligence/wantonness and breach-of-fiduciary-duty

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Robinson v. Montgomery County Board of Education, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robinson-v-montgomery-county-board-of-education-almd-2021.