In Truelove v. Wilson 159 Ga. App. 906 (285 SE2d 556) (1981), the Court reversed the grant of summary judgment to the plaintiffs, finding evidence of gross negligence rather than wanton or wilful conduct, which would have defeated sovereign immunity. Truelove did not involve a public employee's personal liability and entitlement to official or qualified immunity. In Truelove, wilful and wanton conduct was defined as conduct that evidenced "a wilfull intention to inflict the injury, or else was so reckless or so charged with indifference to the consequences as to justify the jury in finding a wantonness equivalent in spirit to actual intent." However, in 1996, our Supreme Court removed reckless conduct from the category of actions that would defeat immunity. The Court concluded "that the drafters intended the 1991 amendment to exclude any liability for injuries and damages if officers and employees act with implied malice in the performance of their official functions," and explained "implied malice" as "conduct exhibiting a 'reckless disregard for human life.'"