Justia Alabama Supreme Court Opinion Summaries

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

A firefighter employed by the City of Birmingham developed hypertension during his employment and applied to the City of Birmingham Retirement and Relief System for both extraordinary and ordinary disability benefits, arguing that his condition and the medications required to control it prevented him from safely performing his job. He detailed unsuccessful attempts to manage his hypertension with various medications and provided medical opinions supporting his claim that only beta-blockers, which are not recommended for firefighters, could control his blood pressure. The Board, after considering the opinion of its medical expert, denied both applications, concluding that he had not exhausted all other antihypertensive regimens.The firefighter sought review of the Board’s decisions by filing a petition for a writ of mandamus in the Jefferson Circuit Court, as permitted by statute. Initially, the circuit court dismissed the action for lack of service, but the Supreme Court of Alabama reversed that dismissal and remanded the case. After service was obtained, the respondents argued that the claim for extraordinary disability benefits failed as a matter of law because the hypertension was not caused by a specific workplace accident, and that the Board’s denial of ordinary disability benefits was not manifestly wrong. The circuit court denied the mandamus petition without a hearing or consideration of evidence beyond the pleadings.The Supreme Court of Alabama affirmed the circuit court’s denial of extraordinary disability benefits, holding that the statutory requirements were not met because the disability did not result from an accident at a definite time and place. However, the Supreme Court reversed the denial of ordinary disability benefits, finding that the circuit court erred by not allowing the petitioner to present evidence or reviewing the evidence considered by the Board. The case was remanded for further proceedings on the ordinary disability claim. View "Hoffman v. City of Birmingham Retirement and Relief System" on Justia Law

A lessor and two lessees entered into a lease with an option to purchase a residential property in Calhoun County, Alabama. The agreement required the lessees to make monthly rent payments, annual payments, and an initial deposit, with certain payments to be credited toward the purchase price if the option was exercised. Disputes arose near the end of the lease term regarding the timeliness of the lessees’ payments and whether the lessees had complied with all contractual requirements, including providing written notice of their intent to purchase.The Calhoun Circuit Court conducted a bench trial and found that a valid lease-to-purchase contract existed, that the lessees had complied with its terms, and that the lessor still owed a mortgage on the property. The court ordered that all funds held by the parties be paid to the lessor to reduce the mortgage principal, required the lessor to satisfy the mortgage and convey clear title to the lessees by a specified date, and assigned responsibility for property taxes to the lessees. The lessor’s postjudgment motion, which challenged the findings regarding compliance and payment timeliness, was denied.On appeal, the Supreme Court of Alabama reviewed the trial court’s factual findings under the ore tenus standard, deferring to the trial court’s credibility determinations unless clearly erroneous. The Supreme Court affirmed the trial court’s finding that the lessees had not breached the lease, concluding that the lessor’s actions had contributed to any payment delays. However, the Supreme Court reversed the trial court’s judgment to the extent it credited monthly rent payments toward the purchase price, holding that only the initial deposit and annual payments should be applied, as the contract unambiguously required. The case was remanded for further proceedings consistent with this holding. View "McCain v. Sneed" on Justia Law

A group of fourteen taxpayers, all out-of-state owners, operators, or lessees of multifamily housing developments in the City of Tuscaloosa, challenged a city ordinance that amended the business-license fee structure. The ordinance, effective April 2022, imposed a 3% business-license fee on rents received from student-oriented housing developments (SOHDs) with more than 200 bedrooms, while other rental properties remained subject to a 1% fee. The SOHD designation is determined by the city’s zoning officer based on a non-exhaustive list of characteristics and factors. The taxpayers alleged that the ordinance unfairly targeted out-of-state owners and was vague in its application.The taxpayers filed suit in the Tuscaloosa Circuit Court, seeking a declaration that the ordinance was invalid and a refund of taxes paid. They raised claims under the Equal Protection and Due Process Clauses, the dormant Commerce Clause, and argued that the ordinance was essentially a zoning ordinance adopted without following statutory notice requirements. The trial court granted the City’s motion to dismiss under Rule 12(b)(6), finding the complaint insufficient to state a claim.On appeal, the Supreme Court of Alabama reviewed whether the complaint alleged sufficient facts to survive dismissal. The court held that the taxpayers’ claims under the Equal Protection Clause, Due Process Clause (vagueness), and dormant Commerce Clause were sufficiently pleaded to withstand a motion to dismiss, as the allegations, if proven, could entitle the taxpayers to relief. However, the court affirmed the dismissal of the claim that the ordinance was a zoning ordinance subject to statutory notice requirements, finding the ordinance did not regulate property use in the manner of zoning laws. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "Campus Crest at Tuscaloosa LLC v. City of Tuscaloosa" on Justia Law

The case involves a dispute between the operator of a day-care center and various officials and employees of the Alabama Department of Human Resources (ADHR) and the Elmore County Department of Human Resources (EDHR). The operator applied to renew the day-care’s license, but a background check revealed that one employee, V.F., had a prior indicated report for child abuse. ADHR officials informed the operator that the license could not be renewed unless V.F. was terminated or cleared. After V.F. was terminated, further disputes arose regarding documentation and access to the facility. ADHR officials subsequently reported alleged deficiencies, leading to the temporary suspension and eventual revocation of the day-care’s license, as well as the operator’s arrest. The criminal charges were later dismissed, and after an administrative hearing, the day-care was relicensed.Previously, the administrative law judge (ALJ) conditionally affirmed ADHR’s decision to revoke the license but allowed for relicensing if the facility met standards. The Montgomery Circuit Court affirmed the ALJ’s decision, and the Alabama Court of Civil Appeals dismissed a further appeal as moot after the license was reissued. The operator and the day-care then filed a new lawsuit in circuit court against the DHR employees, alleging various torts and seeking declaratory relief. The DHR employees moved to dismiss, arguing collateral estoppel based on the prior administrative proceedings. The circuit court granted the motion, dismissing the claims.The Supreme Court of Alabama reviewed whether the circuit court properly dismissed the claims on collateral estoppel grounds. The Court held that, because the circuit court considered materials outside the complaint, the motion to dismiss was converted to a summary judgment motion. The Court found that the plaintiffs failed to adequately argue that collateral estoppel did not apply and affirmed the circuit court’s judgment. The Supreme Court of Alabama thus affirmed the dismissal of the claims. View "Williams v. Dodd" on Justia Law