Hartley v. Agnes Scott College

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In the spring of 2009, Haley Maxwell was a student at Agnes Scott College in Decatur, Georgia. Maxwell reported that she had been beaten and brutally sexually assaulted in her dorm room during the early morning hours of April 13 by a University of Tennessee graduate student named Amanda Hartley. Maxwell also told the officers that on April 27 (two weeks after the alleged attack in her dorm room) she went alone to Hartley's apartment in Knoxville, where Hartley beat her again. A reasonable investigation would have revealed that Maxwell's accusations against Hartley were demonstrably false. Instead, on April 30, without investigating the truth or falsity of Maxwell's story, officers obtained warrants for Hartley's arrest on charges of aggravated sexual battery, battery, and sexual battery. He then contacted the Knoxville Police Department to cause Hartley's arrest and extradition to Georgia. Hartley was arrested and detained in Tennessee on May 6, extradited to Georgia on May 17, and not released on bond until May 28. In December, the district attorney dismissed all charges against Hartley after a reasonable investigation uncovered evidence showing that she was not in Georgia at the time of the alleged assault in Maxwell's dorm room. In April, 2011, Hartley filed a tort lawsuit against Agnes Scott College and three of its campus police officers, alleging that the three officers were acting within the scope of their employment by the college at the relevant times. The complaint sought compensatory and punitive damages based on claims of false arrest, false imprisonment, and intentional infliction of emotional distress. The officer defendants answered and filed a motion to dismiss the complaint, arguing that they were entitled to immunity. The trial court denied the motion to dismiss, but the Court of Appeals reversed. After considering the Georgia Tort Claims Act (GTCA) as a whole, rather than only its definitions section, the Supreme Court disagreed with a three-judge panel of the Court of appeals that concluded the officers were entitled to immunity. "[I]t was clear from the trial court record that the Agnes Scott officers were not acting for any state government entity when they committed the alleged torts." The Court therefore reversed the Court of Appeals' plurality opinion. View "Hartley v. Agnes Scott College" on Justia Law