Ex parte Alabama Department of Youth Services, et al.; Alabama Dept. of Youth Services, et al. v. Roberts, [Ms. SC-2023-0627; SC-2023-0628, Mar. 29, 2024] __ So. 3d __ (Ala. 2024). The Court (Shaw, J.; Parker, C.J., and Bryan, Sellers, Mendheim, Stewart, Mitchell, and Cook, JJ., concur) reverses the Montgomery Circuit Court’s amended stay order, and grants in part and denies in part Defendants’ mandamus petition based on immunity.
This consolidated appeal and mandamus petition stems from a wrongful termination case brought by Derrick Roberts, a former employee of the Alabama Department of Youth Services (“DYS”), against DYS, other agency defendants, and certain individual defendants in their official capacities. Defendants moved to dismiss Roberts’s action on immunity grounds. The trial court denied the motion to dismiss and entered an injunction requiring DYS to continue to employ Roberts pending resolution of the case. Defendants appealed from the injunction and filed a mandamus petition challenging the denial of their motion to dismiss.
As to the motion to dismiss, the Court finds that DYS and the other agency defendants “are ‘absolutely immune from suit,’” Ms. *15. However, applying the exceptions recognized in Ex parte Wilcox Cnty. Bd. of Educ., 279 So. 3d 1135, 1140-42 (Ala. 2018), the Court determines that Roberts’s official capacity claims against several individual defendants seeking a judgment declaring Roberts’s rights under §16-24C-4 and injunctive relief are not barred by sovereign immunity. Ms. **16-17.
The Court reverses the trial court’s preliminary injunction requiring Roberts’s continued employment during the pendency of the case. The Court reiterates that Rule 65(d)(2), Ala. R. Civ. P., requires that every order granting an injunction shall set forth the reasons for its issuance in specific terms. Ms. *21. Here, the trial court’s single-sentence amended stay order awarding injunctive relief fails to satisfy the mandatory requirements of Rule 65(d)(2).