Reynolds v. Hamilton Cty. Dev. Disabilities Servs.
Case Details
- Judge(s)
- Winkler
- Status — whether other courts must follow this ruling
- Published
- Procedural Posture — the stage the case had reached
- summary judgment - reversed on appeal
Related Laws
No specific laws identified for this ruling.
Outcome
Trial court erred in denying defendant's summary judgment motion. Appellate court reversed, finding the political subdivision and its employees were immune from liability under state law because plaintiff was not their employee but an independent contractor, and plaintiff failed to establish exceptions to governmental immunity.
Excerpt
POLITICAL SUBDIVSION IMMUMITY - APPELLATE REVIEW/CIVIL - DEFAMATION – POLITCAL SUBDIVISION EMPLOYEE IMMUNITY: The trial court erred by denying defendant political subdivision's motion for summary judgment on the basis that it was immune from liability where there remained no genuine issue of material fact that plaintiff was not an employee of defendant but an independent contractor: the plaintiff worked for a separate agency, received his paychecks from that agency, received no payments from defendant, was not required to sign off on defendant's policies but had to follow his agency's policies, and defendant did not have authority over the agency's employees. Where the trial court denies a motion in which a political subdivision or its employee seeks immunity, that order denies the benefit of an alleged immunity and is a final order under R.C. 2744.02(C) and, because a determination of immunity can be made prior to investing time, effort, and expense of courts, attorneys, parties, and witnesses, where only issues of law exist as to the issue of immunity, an appellate court may decide the appeal based on those issues of law. Defendant, a political subdivision that provided services to developmentally-disabled individuals, was engaging in a governmental function and was entitled to the general grant of immunity under R.C. 2744.02(A) and because plaintiff did not meet his burden of establishing that one of the exceptions to immunity in R.C. 2744.02(B) applied, defendant is immune from liability. While the tort of defamation may be either negligent or intentional, plaintiff alleged only intentional conduct, and political subdivisions are immune from intentional torts. The trial court erred in failing to find that the employees of the political subdivision were immune from liability where plaintiff failed to show that the employees' actions or omissions were manifestly outside the scope of their employment or that their acts or omissions were with malicious purpose, in b
What This Ruling Means
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