Justia Alabama Supreme Court Opinion Summaries

Hembree Insurance Trust ("Hembree") leased a 135,847-square-foot industrial building in Scottsboro to Maples Industries, Inc. ("Maples") for five years starting January 1, 2020. The lease required Maples to maintain the property and share roof repair costs with Hembree. Hembree initiated a lawsuit against Maples in March 2024, alleging that Maples failed to repair or replace the roof as required by the lease.The Jackson Circuit Court treated Maples's motion to dismiss as a motion for summary judgment and ruled in favor of Maples. The court found the lease "null and void" because Hembree did not own the property, which had been transferred to Woods Cove Industrial Property, LLC ("Woods Cove") in 2014. Hembree argued that it was the sole member of Woods Cove and had the authority to lease the property, but the trial court disagreed.The Supreme Court of Alabama reviewed the case de novo. It found that Hembree, as the sole and controlling member of Woods Cove, had the authority to lease the property. The court noted that a tenant in possession generally cannot dispute the landlord's title and that Maples had accepted and benefited from the lease. The court concluded that Maples was estopped from challenging the lease based on Hembree being the named lessor. The Supreme Court of Alabama reversed the trial court's judgment and remanded the case for further proceedings. View "Hembree Insurance Trust v. Maples Industries, Inc." on Justia Law

In August 2023, the Water Works and Sewer Board of the City of Gadsden ("Gadsden Water") filed a lawsuit in the Etowah Circuit Court against several corporate defendants, including DuPont De Nemours, Inc., and Daikin America, Inc., alleging contamination of its raw-water intake from the Coosa River with perfluoroalkyl and polyfluoroalkyl substances (PFAS). Gadsden Water claimed that the defendants' actions led to substantial economic and consequential damages, including costs for future filtration systems, monitoring contamination levels, and remediation of contaminated property.Previously, in September 2016, Gadsden Water had filed a similar lawsuit ("Gadsden I") against other parties for PFAS contamination, which was settled before trial. The settlement funds were intended to cover the costs of a new water-treatment facility and its long-term operation. The Etowah Circuit Court denied motions to dismiss the current case, leading the defendants to file petitions for writs of mandamus with the Supreme Court of Alabama.The Supreme Court of Alabama reviewed the petitions. For DuPont and Daikin, the Court found that Gadsden Water's claims were barred by the applicable statutes of limitations, as the claims accrued no later than September 2016, when Gadsden Water first became aware of the PFAS contamination. The Court granted the petition for writ of mandamus, directing the Etowah Circuit Court to dismiss the claims against DuPont and Daikin.For INV Performance Surfaces, LLC, the Court determined that the Etowah Circuit Court lacked specific personal jurisdiction. INV's limited contacts with Alabama, including owning equipment in one or two Alabama carpet mills in 2006, were insufficient to establish jurisdiction. The Court granted INV's petition for writ of mandamus, directing the Etowah Circuit Court to dismiss the claims against INV. View "Ex parte DuPont De Nemours, Inc." on Justia Law

Sara Pearl Fahrmann filed a complaint against the City of Orange Beach and D.R. Horton, Inc., alleging that the City failed to ensure that Horton's construction of the Cypress Village subdivision complied with the City's zoning ordinance and the approved Planned Unit Development (PUD). Fahrmann claimed that this failure led to inadequate parking, which obstructed emergency services and delayed treatment for her husband, resulting in his death. She asserted wrongful-death claims based on wantonness and negligence.The Baldwin Circuit Court denied the City's motion for summary judgment, which argued that the City was entitled to substantive immunity from Fahrmann's claims. The City then petitioned the Supreme Court of Alabama for a writ of mandamus to direct the circuit court to grant its motion for summary judgment.The Supreme Court of Alabama reviewed the case and held that the City was immune from Fahrmann's wrongful-death claim alleging wantonness under § 11-47-190, Ala. Code 1975, which limits municipal liability to injuries caused by neglect, carelessness, or unskillfulness, and does not include wanton conduct. The Court also held that the City was entitled to substantive immunity from the negligence claim, as the City's failure to enforce its zoning ordinance did not create a legal duty to individual plaintiffs. The Court granted the City's petition and issued a writ of mandamus directing the circuit court to grant summary judgment in favor of the City. View "Ex parte City of Orange Beach" on Justia Law

In the summer of 2023, Sharonda Smith's minor child, K.S., participated in a summer program at a school operated by the Jefferson County Board of Education. On June 5, 2023, K.S. fell asleep on a bus driven by "Mr. Josh" and suffered significant emotional distress, dehydration, and other personal injuries. Smith filed a lawsuit on May 10, 2024, against the Board, "Mr. Josh," and 10 fictitiously named defendants. The Board moved to dismiss the claims against it, citing State immunity.The Jefferson Circuit Court dismissed the claims against the Board on August 1, 2024, but allowed Smith additional time to identify and serve "Mr. Josh." Smith issued subpoenas to the Board for records related to the incident, which the Board moved to quash, arguing the court lacked subject-matter jurisdiction. The court denied the motion and ordered the Board to comply with the subpoenas. Smith later identified "Mr. Josh" as Joshua Dunn and added his estate as a defendant. The Board petitioned the Supreme Court of Alabama for a writ of mandamus to vacate the discovery orders and dismiss the case for lack of jurisdiction.The Supreme Court of Alabama held that the circuit court lacked subject-matter jurisdiction because the only named defendant in the initial complaint, the Board, was entitled to State immunity, and "Mr. Josh" was a fictitiously named defendant. The court granted the Board's petition in part, directing the circuit court to vacate its discovery orders and refrain from issuing further orders against the Board. However, the court denied the Board's request to dismiss the entire action, as the Board, a nonparty, did not demonstrate a clear legal right to such relief. View "Ex parte Jefferson County Board of Education" on Justia Law

Andrew J. Scarborough, as the administrator of the estate of Timothy John Chumney, filed a lawsuit in the Montgomery Circuit Court against Wexford Health Sources, Inc., Deora Johnson, and Shari Barfield. The case involved allegations of negligence and medical malpractice following Chumney's suicide while incarcerated. The defendants initially did not object to the venue in their Rule 12 motions or answers. However, two years after the trial was first set, they moved to amend their answers to raise the defense of improper venue and filed a motion to transfer the case to Limestone Circuit Court. The Montgomery Circuit Court agreed and transferred the case.Scarborough petitioned the Supreme Court of Alabama for a writ of mandamus, arguing that the defendants had waived their defense of improper venue by not raising it earlier. The defendants contended that the transfer was mandatory under § 6-5-546 of the Alabama Medical Liability Act (AMLA), which they claimed allowed for a venue change at any time before trial.The Supreme Court of Alabama reviewed the case and determined that the defendants had indeed waived their right to challenge the venue under Rule 12(h)(1)(A) of the Alabama Rules of Civil Procedure by not including the defense in their initial motions. The court also clarified that § 6-5-546 of the AMLA did not apply because Scarborough did not allege that the acts or omissions occurred in more than one county. Therefore, the general timing provisions of Rule 12(h)(1) remained applicable.The Supreme Court of Alabama granted Scarborough's petition and issued a writ of mandamus directing the Montgomery Circuit Court to vacate its order transferring the case to Limestone Circuit Court. View "In re: Scarborough v. Wexford Health Sources" on Justia Law

Several residents of the City of Muscle Shoals filed a lawsuit against the City, seeking damages for negligence and trespass due to flooding caused by the City's management of a stormwater-drainage pond in their neighborhood. The plaintiffs claimed that heavy rainfall in February 2019 overwhelmed the pond, leading to the flooding of their homes. They argued that the City failed to plan adequately for such events and did not maintain the pond properly.The plaintiffs initially filed their complaint in the Colbert Circuit Court in March 2020, seeking damages for negligence, wantonness, and trespass. They later amended their complaint to drop the wantonness claim and added a request for injunctive relief, which the trial court denied. The City moved for summary judgment, arguing that the claims were barred by § 11-47-190, Ala. Code 1975, and that there was no substantial evidence to support the trespass claim. The trial court denied the City's motion, leading the City to file a petition for a writ of mandamus with the Supreme Court of Alabama.The Supreme Court of Alabama reviewed the case and determined that the City was immune from the plaintiffs' claims under § 11-47-190, Ala. Code 1975. The Court found that the City's decision to plan for 25-year rainfall events was within common municipal practice and did not constitute neglect, carelessness, or unskillfulness. Additionally, the Court concluded that the City's design and maintenance of the pond were not defective within the meaning of the statute. As a result, the Court granted the City's petition and issued a writ directing the trial court to enter a summary judgment in favor of the City, effectively barring the plaintiffs' claims for damages. View "In re: Burrell v. City of Muscle Shoals" on Justia Law

Trista Carter entered into a contract with Johnny Mack Morrow and Martha Morrow to purchase a house and 245 acres for $1,600,000. The contract included provisions for earnest money and an arbitration clause. The sale did not close, and the Morrows sued Carter for breach of contract and sought damages, including the earnest money. They also named Crye-Leike, Inc., the company holding the earnest money, as a defendant.The Franklin Circuit Court reviewed the case and denied Carter's motion to compel arbitration. The court found that the arbitration clause did not apply to disputes arising under paragraphs 11 and 12 of the contract, which included the earnest money dispute. Carter filed a motion to alter, amend, or vacate the judgment, arguing that the breach-of-contract claim was not solely an interpleader action regarding the earnest money. The trial court denied Carter's postjudgment motions by operation of law.The Supreme Court of Alabama reviewed the case and held that the arbitration agreement in the contract specifically excluded disputes related to the earnest money, as outlined in paragraph 12. Therefore, the trial court properly denied the motion to compel arbitration for the interpleader claim. However, the court found that the breach-of-contract claim, which sought damages beyond the earnest money, was subject to arbitration under the contract's arbitration clause. The Supreme Court of Alabama affirmed the trial court's decision regarding the interpleader claim but reversed the decision regarding the breach-of-contract claim and remanded the case for further proceedings consistent with its opinion. View "Carter v. Morrow" on Justia Law

JohnsonKreis Construction Company, Inc. ("JohnsonKreis") served as the general contractor on a hotel-construction project in Birmingham, with Howard Painting, Inc. ("Howard") as a subcontractor. The subcontract agreement included an indemnity provision requiring Howard to indemnify JohnsonKreis for personal injury or death arising from Howard's negligence. Domingo Rosales-Herrera, an employee of a subcontractor working for Howard, died after falling from a window while attempting to load equipment into a trash box on a telehandler owned by JohnsonKreis. The personal representative of Rosales-Herrera's estate filed a wrongful-death lawsuit against both JohnsonKreis and Howard.The Jefferson Circuit Court granted summary judgment in favor of Howard and its insurers, Auto-Owners Insurance Company and Owners Insurance Company (collectively "Owners"), determining that the indemnity provision in the subcontract agreement was legally unenforceable. The court held that Alabama law does not allow for the apportionment of damages in a wrongful-death case, thus precluding proportional indemnification.The Supreme Court of Alabama reviewed the case and reversed the trial court's decision. The Supreme Court held that the subcontract agreement's proportional indemnity provision was legally enforceable under Alabama law. The court noted that parties may enter into agreements allowing for indemnification even for claims resulting solely from the negligence of the indemnitee. The court emphasized that such agreements are valid and enforceable if expressed in clear and unequivocal language.The Supreme Court remanded the case for further proceedings consistent with its opinion, instructing the trial court to consider the parties' evidentiary submissions and arguments regarding the interpretation and application of the disputed provisions of the subcontract agreement and the additional-insured endorsement. View "JohnsonKreis Construction Company, Inc. v. Howard Painting, Inc." on Justia Law

Island Girl Outfitters, LLC (IGO) operated a store called Hippie Gurlz at Eastern Shore Centre, an outdoor shopping mall owned by Allied Development of Alabama, LLC. IGO signed a five-year lease in late 2020 but closed the store after the first year due to slow sales. Allied Development filed a complaint in Baldwin Circuit Court seeking rent and other damages under the lease. The trial court entered a $94,350 judgment in favor of Allied Development against IGO and its owner, Anthony S. Carver, who had personally guaranteed the lease.The Baldwin Circuit Court granted partial summary judgment in favor of Allied Development, finding no genuine issues of material fact regarding IGO's liability for breaching the lease. The court then held a hearing to determine damages, ultimately awarding Allied Development $94,350. IGO and Carver appealed, arguing that Allied Development failed to market and maintain the mall adequately and that they should not be liable for future rent since the storefront was relet shortly after they vacated.The Supreme Court of Alabama reviewed the case de novo regarding the liability determination and under the ore tenus rule for the damages award. The court found that IGO and Carver failed to show that Allied Development had a contractual duty to market and maintain the mall in a specific manner. Therefore, the trial court's summary judgment on liability was affirmed. Regarding damages, the absence of a transcript from the damages hearing meant the court had to presume the trial court's findings were correct. Consequently, the $94,350 judgment was affirmed. View "Island Girl Outfitters, LLC v. Allied Development of Alabama, LLC" on Justia Law

Nancy Walker executed a will in 2011, leaving personal property to her stepchildren and sister, Beatrice Land, and specific real property to Beatrice. In 2020, Nancy executed a new will and a deed, leaving the same property to her stepgranddaughter, Magen Grimes, and Magen's husband, Joseph Culpepper. Nancy died three weeks later. Beatrice contested the validity of the 2020 will and deed, claiming Nancy lacked testamentary capacity and was under undue influence.The Russell Circuit Court held a jury trial, which found the 2020 will and deed invalid. The court entered a judgment on the jury's verdict and denied post-judgment motions from the proponents of the 2020 will and deed. Beatrice's request for costs incurred in challenging the will was also denied.The Supreme Court of Alabama reviewed the case. It affirmed the circuit court's judgment invalidating the 2020 will, finding sufficient evidence that Nancy lacked testamentary capacity. However, it reversed the judgment invalidating the 2020 deed, citing jurisdictional limitations. The court also reversed the denial of Beatrice's request for costs and remanded the case for further proceedings to determine the amount of costs and attorney fees, and who should pay them. View "Boykin v. Land" on Justia Law