Justia Alabama Supreme Court Opinion Summaries

Michael Dixon and Kalie Dixon entered into a contract with Best Choice Roofing Alabama, LLC for the replacement of the roof on their home in Washington County, Alabama. After the work was completed, the Dixons noticed leaks and water damage, and despite contacting the company and providing an opportunity to fix the issues, their concerns were not resolved. They alleged that their house became nearly uninhabitable and sought damages for breach of contract and wantonness.Best Choice Roofing Alabama moved to dismiss the claims for improper venue, pointing to a forum-selection clause in the contract requiring any lawsuits to be brought in Sumner County, Tennessee, under Tennessee law. The Dixons argued that enforcing this clause would be seriously inconvenient and deprive them of their day in court, citing financial hardship, the distance to Tennessee, and the location of evidence and witnesses in Alabama. The Washington Circuit Court denied the motion to dismiss, finding the forum-selection clause clearly unreasonable and the chosen forum seriously inconvenient due to the circumstances faced by the Dixons, including their financial situation and the impact of the alleged damage.The Supreme Court of Alabama reviewed the trial court’s denial of the motion to dismiss through a petition for writ of mandamus. Applying Alabama law, the Supreme Court held that outbound forum-selection clauses are enforceable unless enforcement would be unfair or unreasonable. The Court found that the Dixons failed to meet their burden to show that enforcement would deprive them of their day in court or that extraordinary facts justified disregarding the clause. The Court concluded that the trial court exceeded its discretion and granted the petition, directing the trial court to dismiss the claims against Best Choice Roofing Alabama. View "Ex parte Best Choice Roofing Alabama, LLC" on Justia Law

The dispute centers on the ad valorem tax assessments for a low-income-housing property purchased in 2019 by Southampton 100, LLC. Dissatisfied with the Jefferson County Tax Assessor's valuations for several tax years, Southampton sought adjustments from the Jefferson County Board of Equalization and Adjustments. While the Board reduced some assessments, Southampton remained dissatisfied and filed separate appeals for each tax year. These appeals were consolidated in the Jefferson Circuit Court, where the Alabama Department of Revenue (ADOR) became the appellee.As the consolidated appeal progressed, the parties encountered repeated discovery disputes. ADOR filed multiple motions for sanctions, culminating in a request to depose Southampton’s second corporate representative, who resided in California, in person in Alabama. Southampton argued that requiring travel was unduly burdensome, offering instead to make this representative available via Zoom or for an in-person deposition immediately before trial. However, Southampton never sought a formal protective order. ADOR persisted and, after additional scheduling complications and denied motions, requested dismissal of the appeal as a sanction for alleged noncompliance. The Jefferson Circuit Court granted this request and dismissed Southampton’s appeal with prejudice, without a hearing or explanation.The Supreme Court of Alabama reviewed the case, applying the standard of whether the trial court exceeded its discretion in imposing sanctions. The Court held that dismissal with prejudice is a severe sanction that requires a showing of willful and deliberate disregard for discovery obligations. The record did not support a finding that Southampton acted willfully or intentionally to prevent discovery. Therefore, the Supreme Court of Alabama reversed the circuit court’s judgment and remanded the case for further proceedings. View "Southampton 100, LLC v. Alabama Department of Revenue" on Justia Law

A business dispute arose when an individual agreed to sell her furniture and design company to a limited liability company controlled by two individuals for $2.7 million, with payment to be made in installments. The seller also entered into a consulting agreement to assist in the transition but was terminated a few months later. The seller alleged that she did not receive compensation due under the consulting agreement and that the buyer failed to pay the final installment of the purchase price. She asserted claims for breach of contract, unjust enrichment, fraudulent inducement, and promissory fraud. The defendants counterclaimed and brought in several third parties, but most of those claims were eventually dismissed, leaving several claims—including for declaratory judgment, conversion, slander, breach of contract, and tortious interference—still pending.The Cullman Circuit Court tried only the seller’s promissory fraud and fraudulent inducement claims against the two individual defendants, entering judgment based on a jury verdict for the seller and awarding over $10 million in damages. The court stayed all claims against the corporate defendants after they filed for bankruptcy. Despite multiple claims and parties remaining, the circuit court certified its judgment against the individuals as final under Rule 54(b) of the Alabama Rules of Civil Procedure.Upon review, the Supreme Court of Alabama determined that the circuit court’s Rule 54(b) certification was improper. The Supreme Court found that closely intertwined and factually overlapping claims, counterclaims, and third-party claims remained unresolved, and that proceeding in piecemeal fashion risked inconsistent results and unnecessary duplication. The Supreme Court dismissed the appeal, holding that the circuit court’s order was not properly certified as final and thus was not appealable at this stage. View "Roberson v. Daniel" on Justia Law

A 45-year-old man was convicted in Greene Circuit Court of first-degree rape of his 16-year-old niece, following an alleged incident at his fish-camp trailer. The prosecution presented no physical evidence, instead relying primarily on the niece’s testimony and that of other witnesses to whom she had spoken after the event. A key witness for the State was a supervisor from the Department of Human Resources (DHR), who investigated the allegations but did not interview the defendant. During trial, the DHR supervisor testified that, after her investigation, she found the allegations to be "indicated," meaning DHR found enough evidence to support them. The defendant objected to this testimony, arguing it inappropriately addressed the ultimate issue of guilt, but the trial court overruled the objection.After the jury convicted the defendant and he was sentenced, he moved for a judgment of acquittal or a new trial, raising the issue of the DHR supervisor’s testimony. The trial court denied the motion. The Alabama Court of Criminal Appeals affirmed the conviction, rejecting the argument that admission of the lay-witness testimony about the ultimate issue was improper.The Supreme Court of Alabama reviewed whether the Court of Criminal Appeals had erred in allowing lay-witness testimony that embraced the ultimate issue of guilt, in light of the precedent established in Naylor v. State, 108 So. 3d 1063 (Ala. Crim. App. 2012). The Supreme Court held that the trial court erred by admitting the DHR supervisor's lay opinion on the ultimate issue, that this error was preserved by objection, and that it was not harmless given the centrality of witness credibility and lack of physical evidence. The Supreme Court reversed the decision of the Court of Criminal Appeals and remanded the case for further proceedings. View "Ex parte Randolph" on Justia Law

The plaintiff underwent a vein-ablation procedure on her right leg in August 2016, performed by a physician other than the defendant. She subsequently developed an infection and was treated by the defendant, who performed several irrigation and debridement procedures over the following months. In March 2017, a 4" x 4" piece of gauze was removed from the plaintiff’s wound, raising questions about whether it had been negligently left in the wound during one of the defendant’s procedures or during subsequent wound care. The plaintiff filed a medical-malpractice complaint in July 2018, alleging that the defendant left a sponge in her body during a September 2016 surgery, which the defendant denied ever performing.The Shelby Circuit Court initially denied the defendant’s motion for summary judgment, allowing the plaintiff to proceed with her claims. After depositions and further discovery, the plaintiff sought to amend her complaint to correct the date of the alleged negligent procedure from September 21, 2016, to October 26, 2016, but continued to reference a vein ablation rather than the actual irrigation and debridement procedure. The defendant moved to strike the amended complaint, arguing undue delay and lack of specificity as required by the Alabama Medical Liability Act (AMLA). The circuit court denied the motion to strike and allowed the amendment.The Supreme Court of Alabama reviewed the case on a petition for writ of mandamus. It held that the plaintiff’s delay in amending her complaint was truly inordinate and unexplained, especially given the information available to her and the defendant’s repeated assertion of his rights under AMLA § 6-5-551. The court found that the circuit court exceeded its discretion by allowing the amendment and directed it to vacate its order granting leave to amend and to strike the plaintiff’s first amended complaint. The petition for writ of mandamus was granted. View "Ex parte Taylor" on Justia Law

A young woman was seriously injured when the passenger airbag in a 1998 Infiniti QX4 deployed during a low-speed collision, causing permanent vision loss in one eye. She was wearing her seatbelt at the time. The accident occurred when another vehicle exited a parking lot and collided with the Infiniti. The injured party, initially represented by her mother as next friend, sued the vehicle’s manufacturer, alleging that the airbag system was defectively designed and that safer alternative designs were available at the time of manufacture.The case was tried in the Mobile Circuit Court. During voir dire, two jurors failed to disclose their prior involvement as defendants in civil lawsuits, despite being directly asked. After a jury awarded $8.5 million in compensatory damages to the plaintiff on her Alabama Extended Manufacturer’s Liability Doctrine (AEMLD) claim, Nissan discovered the nondisclosures and moved for judgment as a matter of law, a new trial, or remittitur. The trial court denied all motions, finding that substantial evidence supported the verdict and, although it believed probable prejudice resulted from the jurors’ nondisclosures, it felt bound by Alabama Supreme Court precedent to deny a new trial.On appeal, the Supreme Court of Alabama affirmed the denial of Nissan’s renewed motion for judgment as a matter of law, holding that the plaintiff presented substantial evidence of a safer, practical, alternative airbag design. However, the Court reversed the denial of the motion for a new trial, concluding that the trial court erred in believing it lacked discretion due to prior case law. The Supreme Court clarified that the trial court retained discretion to determine whether the jurors’ nondisclosures resulted in probable prejudice and remanded the case for the trial court to exercise that discretion. View "Nissan North America, Inc. v. Henderson-Brundidge" on Justia Law

The dispute arose when a property owner obtained a building permit from a city and was required, under the city’s standard procedures, to submit a form containing financial information about subcontractors before the city would conduct necessary inspections and issue a certificate of occupancy. The property owner refused to provide the requested information, leading the city to withhold inspections. As a result, the property owner filed suit, seeking a declaratory judgment that the city lacked authority to require such information and requesting an order compelling the city to perform the inspections. The owner also sought damages for delays allegedly caused by the city’s refusal to inspect.After the property owner settled with the city’s building inspector, the case proceeded in the Baldwin Circuit Court. The jury was asked to decide both the declaratory judgment and damages claims, ultimately finding in favor of the property owner and awarding over $3.5 million in damages. The city appealed. The Supreme Court of Alabama, in a prior decision, held that the damages claim was barred by substantive immunity and reversed the damages award, but did not address the declaratory judgment claim, remanding the case for further proceedings.On remand, the Baldwin Circuit Court entered judgment for the property owner on the declaratory judgment claim but did not award damages. The city appealed again. The Supreme Court of Alabama held that, because the inspections had already been completed and all requested relief had been granted or resolved, no justiciable controversy remained. Therefore, the trial court lacked subject matter jurisdiction to enter a declaratory judgment. The Supreme Court of Alabama reversed the trial court’s judgment and remanded the case for dismissal. View "City of Orange Beach v. Boles" on Justia Law

A Georgia limited-liability company owned and operated a hotel in Birmingham, Alabama, which was subject to a $10,710,000 loan secured by a mortgage, an assignment of leases and rents, and other collateral. The loan was eventually assigned to a bank acting as trustee for a mortgage trust. After the hotel owner allegedly defaulted on its loan obligations and mismanaged the property, the bank filed a complaint in the Jefferson Circuit Court seeking the appointment of a receiver to manage the hotel and ensure payment of operating expenses. The court appointed a receiver and issued orders outlining the receiver’s duties, including managing the hotel and paying its expenses.Following the appointment, disputes arose between the hotel owner, the receiver, and the bank regarding whether the receiver was required to pay expenses incurred before the receivership began (“pre-receivership claims”). The hotel owner sought to compel the receiver to pay these claims, while the receiver and the bank objected, arguing that such payments could harm the receivership estate and improperly prioritize unsecured creditors over the secured lender. The circuit court ultimately issued an order in July 2024 clarifying that the receiver was required to pay pre-receivership expenses, prompting the receiver to appeal.The Supreme Court of Alabama reviewed whether the July 2024 order was an appealable interlocutory injunction and whether the circuit court erred in requiring the receiver to pay pre-receivership claims without regard to creditor priority. The court held that the order was injunctive in nature and appealable. It further held that the circuit court exceeded its discretion by requiring the receiver to pay all pre-receivership claims unconditionally, as this could harm the receivership estate and the interests of priority creditors. The Supreme Court reversed the July 2024 order and remanded the case for further proceedings. View "Kolessar v. SJP Investment Partners, LLC" on Justia Law

The case centers on a dispute between a city and a county sheriff regarding the responsibility for accepting and housing individuals arrested by city police officers for on-sight violations of state law, including misdemeanors, at the county jail. In late 2023, the sheriff implemented a policy refusing to accept arrestees from the city without a warrant issued by a county magistrate, even for offenses committed in the presence of city officers. After discussions, the sheriff temporarily relented, and a Memorandum of Understanding (MOU) was executed, allowing the city to transport such arrestees to the county jail. However, this arrangement ended when the sheriff again refused to accept arrestees due to issues with warrant entry procedures and declined to sign a required state form that would have resolved the procedural issue.The Jefferson Circuit Court granted a judgment on the pleadings in favor of the sheriff and the county commission, dismissing the city’s complaint for lack of subject-matter jurisdiction. The trial court found the matter moot, reasoning that the MOU had expired, and concluded that the city’s request amounted to seeking an advisory opinion. The court also dismissed a counterclaim by the county commission.On appeal, the Supreme Court of Alabama determined that the trial court erred in dismissing the complaint for lack of justiciability, finding that a bona fide controversy existed regarding the sheriff’s obligation to accept arrestees without a warrant. However, the Supreme Court of Alabama affirmed the judgment on the pleadings on alternative grounds, holding that no law requires the sheriff to accept arrestees from the city without a warrant, nor is the sheriff required to sign the state form absent a legal obligation. The court concluded that the sheriff and county commission were entitled to judgment as a matter of law. View "City of Birmingham v. Pettway" on Justia Law

An 84-year-old man with a history of dementia was admitted to a hospital after several falls and subsequently transferred to a nursing home for rehabilitation. His wife, acting as his “Authorized Representative,” signed an optional arbitration agreement as part of his admission paperwork. During his stay, the man developed a pressure wound that became septic, leading to his removal from the facility and subsequent death. The wife, as personal representative of his estate, filed a wrongful death lawsuit against the nursing home and its administrator, alleging medical negligence and asserting that the man was incompetent and unable to make decisions for himself at the time of admission.The Mobile Circuit Court reviewed the defendants’ motion to compel arbitration, which was based on the signed agreement. The wife opposed the motion, arguing she lacked authority to bind her husband to arbitration because he was permanently incapacitated due to dementia. She provided medical records and her own affidavit to support her claim of his incapacity. The defendants countered with evidence suggesting the man had periods of lucidity and was not permanently incapacitated. The trial court denied the motion to compel arbitration and later denied a postjudgment motion by the defendants that included additional medical records.The Supreme Court of Alabama reviewed the case de novo. It held that the wife did not meet her burden to prove the man was permanently incapacitated or temporarily incapacitated at the time the arbitration agreement was executed. The Court found that the evidence showed the man had lucid intervals and was at times alert and able to communicate, and that no contemporaneous evidence established incapacity at the time of signing. The Supreme Court of Alabama reversed the trial court’s order and remanded the case, holding that the arbitration agreement was enforceable. View "Mobile Nursing and Rehabilitation Center, LLC v. Sliman" on Justia Law