Alabama Supreme Court partially agrees with trial court in case involving pay to Space Science Exhibit commissioners

By Kasey Schefflin-Emrich | Dec 6, 2018

MONTGOMERY, Ala. (Legal Newsline) – The Alabama Supreme Court affirmed in part and reversed in part a writ of mandamus filed by Alabama Space Science Exhibit Commission officers in a case of alleged noncompliance with compensation laws.

In an opinion filed on Nov. 21, the Supreme Court ruled that the Madison Circuit Court was correct in not dismissing the plaintiffs’ retrospective relief and declaratory relief claims but was wrong in not dismissing the individual capacities claims.

According to the ruling, the Department of Examiners of Public Accounts conducted an audit in October 2013 and found the Commission didn’t comply with Alabama law in its payment of annual longevity bonuses to Commission employees and in the way it compensated employees for working on certain holidays. The audit was released to the public in January 2014.

While the Commission disagreed with the findings, arguing “the legislation pursuant to which the Commission was created, § 41-9-430 et seq., Ala. Code 1975, removed the Commission from the purview of certain state employment laws, including the benefit statutes,” it told employees any required changes would be made, the ruling states.

After no changes were made, several former employees sued the Commission and officers in October 2015, alleging they and other employees didn’t receive all the compensation they should have received.

The plaintiffs made a declaratory-relief claim, seeking a judgment declaring the Commission’s existing policies and compensation plan didn’t comply with the benefits statues; a prospective-relief claim, seeking an injunction requiring the Commission officers to comply with those statutes; a retrospective-reliefs claim, seeking an award of money previously earned but not paid because of the failure to comply with the benefits statutes; and an individual-capacities claim, alleging negligence and breach-of-fiduciary-duty of the officers as individuals.

The plaintiffs also made a motion for class certification of their claims, which the trial court granted for all claims except the prospective-relief claim because “none of the named plaintiffs were current employees of the Commission and because they might, to the detriment of current Commission employees, accordingly be motivated to focus on recovering past damages as opposed to obtaining prospective injunctive relief that would not directly benefit them,” the ruling states.

The trial court certified the class under Rule 23, which requires questions of law or fact common to the class.

“[T]he common issues present here which underlie [the named plaintiffs'] claims are susceptible to classwide proof,” the trial court ruled, as stated in the opinion. “The Commission compensation policy is uniform and has not changed in the relevant time period. This truth, combined with the fact that the Commission's policy on paid holidays and longevity pay is facially inconsistent with the [benefits statutes], indicates that the proof required for [the named plaintiffs] to succeed on their claims is identical to the evidence required by class members.”

In agreement with the trial court in certifying the retrospective claim, the Supreme Court opinion stated the plaintiffs should have received additional compensation pursuant to the benefit statutes and the Commission officers were legally required to make those payments. 

Also in agreement with the certification of the declaratory-relief claim, the Supreme Court stated the plaintiffs would benefit from a declaration that the Commission is bound by the benefits statutes and that declaration is a prerequisite to the plaintiffs obtaining any relief on their claims.

The Supreme Court did disagree with the trial court on the individual-capacities claims and stated “those claims are essentially claims against the State regardless of the manner in which they have been asserted, and the trial court accordingly erred by not dismissing those claims for lack of subject-matter jurisdiction.”

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