Employees of a municipality who are performing governmental functions generally share in the immunity of the municipality itself, although this does not protect them from being sued for gross negligence (as opposed to "ordinary" negligence) or for intentional torts. High-level employees, such as mayors, city managers, and judges, are immune for decisions made within the scope of their employment. The immunity of lower level employees is determined by examining four factors set forth by the Virginia Supreme Court in "James v. Jane":