Brown v. Pound
Alabama Supreme Court
585 So. 2d 885 (1991)
- Written by Haley Gintis, JD
Facts
In March 1988, Dr. Daniel Pound (defendant), who was associated with Decatur Medical Associates (DMA) (defendant) examined Vadine Brown’s grandson at Decatur Medical Surgical Center (center). Brown had brought her grandson to the center to be treated for a burn. After Pound examined Brown’s grandson, he reported to the Morgan County Department of Human Resources (department) that he suspected the burn was a result of child abuse. The department investigated the incident and concluded there was no evidence to support the child-abuse allegation. After the investigation, Brown filed a claim against Pound and DMA. Brown alleged that Pound’s report was groundless and therefore in violation of the Alabama Child Abuse Reporting Act (CARA), that Pound had committed the tort of invasion of privacy, and that Brown had suffered mental and emotional damages as a result of the report. Brown claimed that DMA was liable based on a respondeat superior theory. Pound and DMA moved to dismiss the complaint on the ground that they were entitled to absolute immunity under CARA. The trial court granted the motion. Brown appealed.
Rule of Law
Issue
Holding and Reasoning (Adams, J.)
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