Brief Fact Summary. The Appellants, William Ayala and William Ayala Jr. (William Jr.) (Appellants), brought suit to recover damages after William Jr.’s arm was injured in a shredding machine during class. The Appellee, Philadelphia Board of Education (Appellee), asserted governmental immunity, and the Superior Court affirmed the defense.
Synopsis of Rule of Law. The defense of governmental immunity is no longer applicable in Pennsylvania.
Issue. Should Pennsylvania continue to apply the doctrine of governmental immunity?
Held. No. Judgment reversed and remanded.
* The doctrine of governmental immunity has its historical roots in English law. The theory of respondeat superior created problems with government employees, as the courts routinely denied relief because the King, as employer, could commit no torts. This rule is unjust as applied to modern American law, applying the burden of damages on the single individual who suffers the injury, rather than distributing the damages among the entire community constituting the government.
* This Court also rejects the fear of excessive litigation as justification for the doctrine, as there is little empirical evidence to support the fear. Equally unpersuasive is the argument that governmental units lack the funds from which claims can be paid, as the availability of public insurance disavows such concerns. Additionally, allowing causes of action against governmental units should increase the concern for the welfare of those who might be injured by its actions.
Stare decisis is not a vehicle for perpetuating error, but rather a legal concept that responds to the demands of justice and, thus, permits the orderly growth processes of the law to flourish.View Full Point of Law