Washington State Deputy Sheriff Not Entitled to Quasi-Judicial Immunity
The Washington Court of Appeals held that a deputy sheriff who was negligent in transporting a prisoner from court to jail was not entitled to quasi-judicial immunity.
Anthony Reijm was taken into custody on the order of Skagit County District Judge Stephen Skelton after failing to abide by certain previously-imposed conditions of his release. Sheriff’s Deputy Deanna Randall arrived to take Reijm to jail.
Rather than place Reijm in handcuffs, Randall, who was at least a foot shorter than Reijm, put her hand on his elbow and escorted him on the short walk from the courtroom to the jail. Along the way, Reijm broke free and knocked down John Lallas, a security guard at the courthouse. Reijm was later discovered hiding in a stairwell a few blocks away. Lallas was taken to a hospital via ambulance.
Lallas sued Randall and Skagit County for damages related to the injuries he sustained when Reijm escaped. The defendants contended that they could not be sued because Randall was acting as “an arm of the court” when she carried out Judge Skelton’s order to take Reijm into custody. The trial court agreed, holding the defendants were entitled to quasi-judicial immunity. Lallas appealed.
The doctrine of judicial immunity is designed to protect judges from harassing lawsuits by litigants displeased with a judge’s decisions. Immunity under the doctrine is absolute; it protects judges who act within their judicial capacity from liability for both willful misconduct as well as negligence. Quasi-judicial immunity is an extension of that doctrine. It attaches to “persons or entities that perform functions so comparable to those performed by judges that they ought to share the judge’s absolute immunity while carrying out those functions.” Lutheran Day v. Snohomish County, 829 P.2d 746 (Wash. 1992).
Applying those standards to the facts in this case, the appellate court concluded that the defendants were not entitled to quasi-judicial immunity. Randall performed an executive – not judicial – function when she “chose to take Reijm into custody without using handcuffs,” the Court of Appeals explained. Accordingly, the trial court’s order of dismissal was reversed. See: Lallas v. Skagit County, 144 Wash.App. 114, 182 P.3d 443 (Wash.App. Div. 1, 2008).
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Related legal case
Lallas v. Skagit County
|144 Wash.App. 114, 182 P.3d 443 (Wash.App. Div. 1, 2008)
|State Court of Appeals