Ex Parte State of Alabama Board of Education (in Re: Sharper D. Adams v. State of Alabama Board of Education)

Summary

The court granted the mandamus petition in part and directed dismissal of the federal due-process claim against the state agency, against the officials in their official capacities insofar as damages were sought, and against the officials individually. It held that official-capacity claims for prospective reinstatement were not barred by the Eleventh Amendment, but that the officials were entitled to qualified immunity because the asserted right to notice and a hearing before termination in a bona fide reduction in force was not clearly established. Justice Murdock, concurring in the result, questioned the need to adopt the majority's stated formulation of the clearly established-law standard and found the petition timely based on the jurisdictional nature of immunity.