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Washington Supreme Court Holds No Judicial Immunity for Non-Judicial Conduct

The doctrine of judicial immunity does not apply to actions unrelated to judicial conduct, the Supreme Court of Washington decided on December 31, 2009.

In September 2002, Skagit County District Court Judge Stephen Skelton ordered Deputy Deanna Randall to take Anthony Reijm into custody following a court hearing.

Believing Reijm to be a model prisoner, Randall attempted to escort him to jail without handcuffing him. Instead Reijm made a break for it. John T. Lallas, a private security guard, attempted to block Reijm from running out the front door of the court-house and was injured in the process.

Lallas sued Deputy Randall and Skagit County claiming negligence. The trial court granted summary judgment to both defendants, holding they were entitled to quasi-judicial immunity from suit. After the Court of Appeals reversed, the Washington Supreme Court granted review. [See: PLN, Feb. 2009, p.37].

Deputy Randall and Skagit County argued they were immune from suit because Randall was performing a judicial function when she was escorting Reijm to jail on Judge Skelton’s order. The Supreme Court disagreed.

Judicial immunity applies when the function being performed is in a “judicial capacity,” the Court wrote. In this case Deputy Randall was not performing a judicial function in transporting Reijm to jail, because “[j]udges do not normally escort prisoners to jail as part of their official duties,” the Supreme Court concluded. Accordingly, judicial immunity did not apply be-cause Deputy Randall’s actions did not constitute “judicial conduct.”

The judgment of the Court of Appeals reversing the trial court’s grant of summary judgment to Randall and Skagit County was therefore affirmed. See: Lallas v. Skagit County, 167 Wash.2d 861, 225 P.3d 910 (Wash. 2009).

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