Charles E. Jackson, III v. Metropolitan Government of Nashville et al.

The matters at issue pertain to the alleged negligence of a Davidson County probation officer and the quasi-judicial immunity defense. Plaintiff, a probationer who was arrested and detained in jail on a probation violation warrant, filed this action alleging he was unlawfully arrested and jailed because his probation officer negligently failed to recall a probation warrant after he cured the deficiencies for which it was issued. The trial court granted the probation officer's Tenn. R. Civ. P. 12.02(6) motion to dismiss based on the defense of quasi-judicial immunity because the complaint asserted that she was acting in her capacity as his probation officer when she failed to recall the warrant. Plaintiff insists this was error, contending the probation officer is not entitled to quasi-judicial immunity because she was not performing a function essential to the judicial process and she had no discretion but to recall the warrant. We affirm.