In Westfall v. Erwin (1988) 484 U.S. 292 108 S. Ct. 580, 98 L. Ed. 619 (hereafter Westfall), the court reversed a summary judgment for the defendants, federal employees who worked as supervisors at an Army depot, in a state court negligence action arising from a workplace injury to a civilian employee. The court held that "absolute immunity from state-law tort actions should be available only when the conduct of federal officials is within the scope of their official duties and the conduct is discretionary in nature." (Id., at pp. 297-298 108 S. Ct. at p. 584, italics added.) The Westfall court observed that "official immunity comes at a great cost. An injured party with an otherwise meritorious tort claim is denied compensation simply because he had the misfortune to be injured by a federal official. Moreover, absolute immunity contravenes the basic tenet that individuals be held accountable for their wrongful conduct." (Westfall, supra, 484 U.S. at p. 295 108 S. Ct. at p. 583.) The court further observed that "the central purpose of official immunity, promoting effective government, would not be furthered by shielding an official from state-law tort liability without regard to whether the alleged tortious conduct is discretionary in nature. When an official's conduct is not the product of independent judgment, the threat of liability cannot detrimentally inhibit that conduct." (Westfall, supra, 484 U.S. 292, 296-297 108 S. Ct. 580, 584.) In the case before it, the Westfall court held, summary judgment was improper because the plaintiff had asserted the defendants' duties only required them " 'to follow established procedures and guidelines' " and that they were " 'not involved in any policy-making work . . . .' " The defendants, who had the burden of proving they were immune, had not presented "any evidence relating to their official duties or to the level of discretion they exercise." (Westfall, supra, 484 U.S. at p. 299 108 S. Ct. at p. 585.)