The appeals arose out of a claim that Caremark had procured a class action settlement by fraud. As part of the fraud action, the Plaintiffs asked the trial court, pursuant to Rule 60(b)(6), Ala. R. Civ. P., to reopen the Taff action –– which appears to have seen no activity since it was settled in June 2000 –– and to order Caremark to provide the Taff class counsel with information regarding the members of the Taff class.

In the original settlement, the Court stated in its Order that "[t]he court hereby reserves and maintains continuing jurisdiction over all matters relating to the settlement agreement or the consummation of the settlement." Pursuant to this language, the trial court ordered Defendants to produce information related to the Taff class.

On appeal, Caremark argued that the trial court lacked jurisdiction to enter the order requiring Caremark to produce certain information regarding the members of the Taff class.  The Alabama Supreme Court agreed, and reasoned that “if no Rule 59 motion is filed after a judgment is entered, the trial court that entered the judgment generally loses jurisdiction to amend the judgment 30 days after the judgment is entered.” Further, the Court stated that the trial court “cannot broaden by mere declaration the residual jurisdiction it necessarily holds to allow it to interpret or enforce its judgments.”

Accordingly, because the jurisdiction retained by the trial court after it entered its final judgment in Taff is limited to interpreting or enforcing that final judgment, the trial court could not extend its jurisdiction over any matter somehow related to the June 2000 final judgment in perpetuity by simply declaring it so.

On appeal, the defendant teachers challenged the trial court’s denial of their Motion for Summary Judgment arguing that they are entitled to summary judgment based on State-agent immunity. The Alabama Supreme Court examined the standard used to determine when a State employee is entitled to State-agent immunity, which provides in pertinent part that: “[a] State agent acts beyond authority and is therefore not immune when he or she fails to discharge duties pursuant to detailed rules or regulations, such as those stated on a checklist."'

The teachers argued that the rules in question were not sufficiently detailed to establish that the teachers acted "beyond their authority" in regard to the circumstances with which they were confronted in this case. The Court recognized that there must be a fact intensive inquiry into whether a relevant guideline leaves room for the exercise of any discretion or professional judgment by the employee in relation to the particular circumstances with which the employee may be presented. In reviewing the approach followed by the majority of states, Alabama cited with approval the rule that determines whether a State agent is acting beyond her authority when following a regulation.  Namely, a State agent may be found to be acting beyond her authority when “the guideline was so specific to the particular circumstances presented as to leave no room for professional judgment or discretion on the part of the teacher.”

Based on this rule, the Court concluded that there existed a question of fact as to whether the teachers were acting beyond their authority based on the language of the school’s policy that was allegedly violated.