Wayne Morrow v. Shameka Caldwell, as Mother and Next Friend of Keandarick Russell, a Minor

Summary

The Supreme Court of Alabama affirmed the denial of a municipal employee’s request for a declaration that the statutory damages cap applied to claims against him in his individual capacity. Construing the statute as a whole, the court held that the cap limits recovery arising from the municipal liability authorized by the statute, including official-capacity claims and indemnity obligations, but does not limit individual-capacity claims against municipal employees. Justice Murdock concurred specially, agreeing with the result while emphasizing the statutes’ historical context and reserving questions concerning any personal duty owed by the employee.