Ex Parte Phenix City Board of Education. (in Re the Lisle Company, Inc. v. Phenix City Board of Education)

Summary

The Supreme Court of Alabama granted the Phenix City Board of Education’s petition for mandamus, reversing the circuit court’s denial and ordering dismissal of the breach‑of‑contract and quantum meruit claims brought by The Lisle Company. The Court held that, as a city board of education, the Board is a state agency entitled to absolute immunity under § 14, Ala. Const. 1901, which bars all civil actions against it. A specially‑concurring opinion agreed with the result and emphasized the need to name a state official and fit within the six statutory exceptions to overcome immunity.