North Carolina Court of Appeals Affirms Doctrine of Governmental Immunity for Public Officials in Correctional Facility Healthcare Services Context

On October 5, 2021, the North Carolina Court of Appeals issued an opinion in the matter of Butterfield v. Gray, No. COA20-218, 2021, and reversed a trial court’s denial of summary judgment against Wilson County and employees of the Wilson County Sheriff’s departments’ claims of governmental immunity.  The Butterfield case involved an inmate, Todd Caveness, who was arrested and detained at the Wilson County Detention Center in 2016.  Plaintiffs, co-Administrators of the Estate of Mr. Caveness, instituted an action against the Wilson County Sheriff and two Sheriff’s Deputies (“Sheriff Defendants”) alleging negligence and liability of Wilson County, wanton conduct, and violation of Mr. Caveness’ constitutional rights. The Sheriff Defendants subsequently moved for summary judgment as to Plaintiffs’ claims arguing that governmental immunity barred the claims against them in their official capacities. 

Reversing the trial court’s order denying the Sheriff Defendants’ motion for summary judgment, the Court of Appeals held that sheriffs and sheriff’s deputies are deemed public officials and may avail themselves to the doctrine of governmental immunity.  Governmental immunity will apply to public officials in the broad operation of a detention center and its provision of medical services in a detention center as a governmental function.  The Court also reviewed several bases for potential waiver of governmental immunity, including purchase of liability insurance and the purchase of a Sheriff’s Bond.  Ultimately the Court held that the Sheriff Defendants had not waived governmental immunity as to any claims for damages in excess of the amount of the Sheriff’s Bond.  The Court also affirmed the constitutionality of the doctrine of governmental immunity and reviewed the holdings of numerous cases setting precedent establishing the constitutionality of the doctrine of governmental immunity.