With no explanation, chose the best option from "A", "B", "C" or "D". properly determined that Appellants’ motion could withstand challenge. THE IMMUNITY ISSUE Appellants next contend that Horowitz is a public officer who is immune from suit. Preliminarily we note that this cause of action accrued after the Pennsylvania Supreme Court decided Ayala v. Philadelphia Board of Public Education, 453 Pa. 584, 305 A.2d 877 (1973) (which abolished the doctrine of governmental immunity) and before the adoption of the Political Subdivision Tort Claim Act, 42 Pa. C. S. §§8541-8542. Thus, the Township has no immunity from suit. But Ayala did not involve the issue of im munity granted a public official. Accordingly, Horowitz could have a defense which is unavailable to the Township. See Wicks v. Milzoco Builders, Inc., 25 Pa. Commonwealth Ct. 340, 360 A.2d 250 (1976) (<HOLDING>). Whether or not Horowitz falls within the

A: holding that township supervisors absolute immunity from suit because of their positions as high public officials may not be used to shield the township itself from liability
B: holding immunity from liability is not jurisdictional
C: holding township equitably estopped from terminating officers postretirement health benefits
D: holding that one of the principal purposes of the qualified immunity doctrine is to shield officers not only from liability but also from defending against a lawsuit
A.