Justia Alabama Supreme Court Opinion Summaries

Tara Grall and her former husband, William Grall, were the sole shareholders of G-Team, P.C., an Alabama professional corporation that had ceased business operations. Amid their divorce proceedings, William initiated a derivative action against Tara, seeking to enforce the corporation's right to sell its real property to pay off mortgage debt. Tara argued that the property could not be sold due to an existing Small Business Administration lien. The trial court ordered the sale of the property and scheduled a hearing to determine the distribution of proceeds and finalize the winding up of G-Team. Tara, representing herself, filed multiple motions, including requests to stay hearings, appear remotely, and recuse the judge, but these were denied.Tara appealed several interlocutory orders to the Alabama Court of Civil Appeals, describing her appeal as interlocutory and requesting a stay, which was denied. Despite her pending appeal, the trial court conducted a final hearing and entered a purported final judgment on May 1, 2025, winding up G-Team. Tara then appealed that judgment as well. The Court of Civil Appeals transferred both appeals to the Supreme Court of Alabama, citing a lack of subject-matter jurisdiction.The Supreme Court of Alabama determined it lacked jurisdiction over both appeals. It held that the first appeal was not from a final judgment nor from an appealable interlocutory order under Rule 4(a)(1), Alabama Rules of Appellate Procedure, and therefore must be dismissed. The second appeal was from a judgment entered while the first appeal was pending, at which point the trial court was divested of jurisdiction; this made the subsequent judgment void and the second appeal also subject to dismissal. Both appeals were dismissed by the Supreme Court of Alabama. View "Grall v. Grall" on Justia Law

A woman called 911 to request a welfare check on her elderly neighbors’ home after noticing an unfamiliar vehicle and a young Black male there while the neighbors were out of town. When Officer Smith of the Childersburg Police Department arrived, he found a man watering flowers and asked if he lived at the house. The man, who identified himself as Pastor Jennings and said he lived across the street, explained he was watching the house for the neighbors. When asked for identification, Jennings became agitated and refused to provide any. Other officers arrived, and after Jennings repeatedly refused to further identify himself, he was arrested and charged with obstructing a governmental function.After the charge was dismissed, Jennings sued the officers and the City of Childersburg in the United States District Court for the Northern District of Alabama, alleging unlawful and retaliatory arrest under federal law and false arrest under state law. The district court granted summary judgment and dismissal in favor of the officers and the City, finding that Jennings violated Alabama’s stop-and-identify statute, Ala. Code § 15-5-30, by refusing to give his complete name. The United States Court of Appeals for the Eleventh Circuit reversed, relying on a prior interpretation of the statute that prohibited officers from demanding physical identification. On remand, the district court found the law’s interpretation uncertain and certified a question to the Supreme Court of Alabama.The Supreme Court of Alabama held that Ala. Code § 15-5-30 does not prohibit law enforcement officers, during a valid Terry stop, from requesting physical identification if a suspect gives an incomplete or unsatisfactory oral response regarding their name and address. The court clarified that suspects must provide sufficient identifying information and that failure to do so can constitute a violation of Alabama law. View "Jennings v. Smith" on Justia Law

A married couple who had served as foster parents were indicted for capital murder in connection with the death of an infant, E.E., who had been placed in their care by the Marshall County Department of Human Resources due to his medical needs and his parents’ inability to care for him. The child, who required a feeding tube and frequent hospitalization, died while in their custody. In July 2024, a Blount County grand jury indicted both individuals for capital murder, and they were denied bail by the Blount Circuit Court after evidentiary hearings.The petitioners each moved for bail, arguing that the State had the burden to present evidence sufficient to show they were not entitled to bail. The State countered that, in capital cases, the indictment itself creates a presumption of guilt for purposes of bail, and the burden shifts to the defendants to overcome this presumption. The Blount Circuit Court agreed with the State, denied bail, and found that the evidence did not overcome the presumption arising from the indictment. The Court of Criminal Appeals subsequently denied habeas petitions challenging the denial of bail.Upon review, the Supreme Court of Alabama reaffirmed the longstanding “presumption rule,” which holds that, in capital cases, an indictment creates a presumption of guilt for purposes of bail, and the defendant must overcome this presumption by presenting sufficient evidence. The Court declined to overturn this rule, citing stare decisis and legislative acquiescence, especially in light of recent constitutional and statutory amendments. The Court held that the trial court did not err in denying bail because the petitioners had not overcome the presumption of guilt, and it denied both petitions for writs of habeas corpus. View "State of Alabama v. Grimes" on Justia Law

Brian Smith, through several companies he formed, was engaged in purchasing and developing property around Lake Martin. In March 2025, Smith and his companies initiated arbitration proceedings with the American Arbitration Association, asserting claims such as fraud and breach of contract against various individuals and entities involved in the land transactions. These respondents, who were involved in the transactions as real estate agents, agencies, a closing agency, and a consultant, had not signed the contracts containing the arbitration provisions at issue.In response, the individuals and entities named in the arbitration, now plaintiffs, filed a declaratory-judgment action in the Tallapoosa Circuit Court. They sought a judgment declaring there was no valid and enforceable agreement requiring them to arbitrate disputes with Smith and his companies and requested a stay of the arbitration. The defendants moved to compel arbitration based on provisions in the relevant land-sale contracts, arguing that even as nonsignatories, the plaintiffs were bound by the arbitration clauses due to equitable estoppel or because they were third-party beneficiaries. The defendants further contended that the question of arbitrability—whether the claims against the plaintiffs should be arbitrated—was itself a matter for the arbitrator, not the court, to decide. The circuit court disagreed, stayed the arbitration, and decided it would determine whether a valid arbitration agreement existed.The Supreme Court of Alabama reviewed the matter and held that, under its precedent, when an arbitration provision contains a delegation clause or incorporates the AAA rules, the question of whether claims against nonsignatories are subject to arbitration must be decided by the arbitrator. The Court concluded the circuit court erred in staying the arbitration and in failing to compel arbitration. The Court reversed the circuit court’s order and remanded the case for entry of an order compelling arbitration. The petition for writ of mandamus was dismissed as moot. View "Ex parte Smith" on Justia Law

After both parents contracted COVID-19 in 2020, they asked their daughter to move from Tennessee to Alabama to care for them. In exchange for her agreement to relocate and provide care, the parents promised to convey an interest in their Orange Beach condominium to the daughter. The parents, acting in their individual capacities, executed a deed purporting to transfer an interest in the property to themselves and their daughter as joint tenants. The daughter was not aware that the condominium was, in fact, owned by a revocable trust for which the parents served as trustees.The parents later sought to annul the deed in the Baldwin Circuit Court, arguing that the deed was ineffective because the property was owned by the trust and they had not executed the deed as trustees. They also contended that the conveyance was voidable under Alabama law because a material part of the consideration was the daughter’s promise to support them. The daughter sought reformation of the deed to reflect the parents' trustee status and counterclaimed for fraud and breach of warranty. The Baldwin Circuit Court annulled the deed and dismissed the daughter’s counterclaims.The Supreme Court of Alabama reviewed the case. It held that the controlling statute, § 8-9-12, Ala. Code 1975, permitted annulment of a real property conveyance when a material part of the consideration was an agreement to provide support, regardless of whether the grantor acted as an individual or trustee. The Court further held that annulment of the deed extinguished any warranties arising from the conveyance and rendered the fraud counterclaim untenable. Accordingly, the Supreme Court of Alabama affirmed the judgment, upholding annulment of the deed and dismissal of the counterclaims. View "Schumpert v. Wallace" on Justia Law

Fifteen local United Methodist Church congregations in Alabama initiated civil actions against the Alabama-West Florida Conference of the United Methodist Church, Inc., seeking to quiet title to the church properties they occupied and used for worship. The Conference and its board of trustees joined the cases and filed counterclaims, asserting that the properties were either owned by the Conference’s board or held by the local churches in trust for the Conference or its board. Both sides relied primarily on secular documents, such as deeds and corporate records, though the Conference also referenced trust provisions in the Book of Discipline.Trial courts in various counties reviewed the motions by the local churches to dismiss the Conference’s counterclaims, arguing that the courts lacked subject-matter jurisdiction under the ecclesiastical-abstention doctrine, which prohibits courts from resolving matters of church doctrine or internal governance. The trial courts granted the motions to dismiss the counterclaims but allowed the local churches’ quiet-title claims to proceed. The Conference and its board then petitioned the Supreme Court of Alabama for writs of mandamus, seeking to overturn the dismissals.The Supreme Court of Alabama determined that the trial courts erred in dismissing the counterclaims for lack of subject-matter jurisdiction. The Court held that the property disputes could be resolved under neutral principles of law without requiring the courts to decide ecclesiastical matters. Because both parties relied on the same secular materials, and the counterclaims did not require adjudication of religious doctrine, the ecclesiastical-abstention doctrine did not bar jurisdiction. The Supreme Court issued writs of mandamus, directing the trial courts to vacate their orders dismissing the Conference’s counterclaims. View "Mt. Zion of Autauga County, Inc. v. Alabama-West Florida Conference of the United Methodist Church, Inc." on Justia Law

An apartment complex owned by Kinsman Investments suffered roof and siding damage during Hurricane Katrina in 2005. The complex was insured by Alfa Mutual Insurance Company, and Alfa's adjuster, Jeffery Dimoff, worked with Kinsman’s owner to arrange repairs. Kinsman later alleged that Alfa and Dimoff convinced it to use less expensive materials, misrepresenting that higher-quality materials were unavailable or unsafe, and failed to disclose a policy provision allowing compensation for differences in material quality. Kinsman claimed it was unaware of this provision and relied on Dimoff’s interpretation of the policy. In 2022, Kinsman sued Alfa and Dimoff for fraud, fraudulent suppression, and bad faith/breach of contract, seeking damages for the alleged diminished value of the property.The Mobile Circuit Court reviewed the case. Alfa and Dimoff moved for summary judgment, arguing all claims were barred by statutes of limitations, since Kinsman knew of the material differences and had a copy of the policy in 2005 and 2006, but waited until 2022 to file suit. The trial court denied the motions for summary judgment. Alfa and Dimoff sought permission to appeal, which was denied, and then filed a petition for a writ of mandamus.The Supreme Court of Alabama reviewed the petition. It held that Alfa and Dimoff had a clear legal right to summary judgment because the complaint showed the claims accrued in 2006, making the 2022 lawsuit untimely under applicable statutes of limitations. The Court also found that no adequate alternative remedy existed, as further litigation would impose undue burdens. The Court issued the writ of mandamus, directing the trial court to vacate its denial of summary judgment and to enter summary judgment in favor of Alfa and Dimoff. View "Ex parte Alfa Mutual Insurance Company" on Justia Law

A teacher who had previously attained tenure in the Montgomery County public-school system resigned from that position in September 2019 after accepting an offer for a probationary teaching job with the Alabama Department of Youth Services School District (DYS). The teacher received an email in mid-September confirming the job offer, with instructions to begin work on October 7, 2019, after completing mandatory training. The teacher’s salary, benefits, and job responsibilities with DYS all began on October 7, and he completed multiple school years in the new role before receiving notice in April 2023 that his contract would not be renewed.The teacher filed suit in the Montgomery Circuit Court, seeking a declaration that he had acquired tenure under the Students First Act of 2011, which would entitle him to due-process protections before dismissal. The trial court held a bench trial and concluded that the teacher was tenured at the time of his nonrenewal, reasoning that his employment was “effective” upon the agreement in September 2019 and, in the alternative, that DYS was estopped from denying him tenure because he relied on the September email when resigning from his previous tenured position.On appeal, the Supreme Court of Alabama reversed the trial court’s decision. It held that, for purposes of the Students First Act, “effective employment” occurs when a teacher is required to report for work and is paid, not at the time of an offer or acceptance. Because the teacher’s employment with DYS became effective on October 7, 2019—after the statutory October 1 cutoff—he did not accrue a “complete” school year for 2019-2020 and did not acquire tenure before his contract was nonrenewed. The Court also rejected the application of equitable estoppel, finding no misleading conduct by DYS. The judgment was reversed and the case remanded. View "Smitherman v. Roberts" on Justia Law

A woman visited a Huntsville shopping center in May 2021, where renovations were underway, including the installation of new sidewalks in front of a Staples store. The construction zone was marked with barricades, caution tape, signage, and fluorescent paint to warn pedestrians of uneven concrete resulting from recent work. Despite these measures, the woman tripped and fell while walking through the marked area, attributing her fall to a slight elevation change in the concrete. She later filed suit against the property owner, the general contractor, a concrete-cutting subcontractor, and Staples, alleging negligence, wantonness, premises liability, and respondeat superior.The Madison Circuit Court entered summary judgment in favor of the shopping center owner and the general contractor, finding no genuine issue of material fact. The subcontractor was dismissed by agreement, and the plaintiff later settled with Staples’ successor. The circuit court did not specify its reasoning for the decision. After her postjudgment motion failed, the plaintiff appealed.The Supreme Court of Alabama reviewed the summary judgment de novo, considering whether the alleged hazard was open and obvious, which would negate the defendants’ duty to warn or maintain. The court concluded that, as a matter of law, the multiple warnings—including barricades and fluorescent paint—rendered the uneven concrete an open and obvious condition to a reasonable person. Therefore, the defendants owed no additional duty to warn, and the plaintiff’s claims for negligence and wantonness failed as a matter of law. The Supreme Court of Alabama affirmed the judgment of the Madison Circuit Court. View "Walter v. Branch Hays Farm SC Associates, LP" on Justia Law

A homeowner alleged that he hired a roofing company in 2011 to install a specific type of roof on his residence. After installation, problems with roof materials became apparent, including issues with a protective layer that remained unresolved despite multiple repair attempts by both the roofing company and the manufacturer over more than a decade. The homeowner asserted that these defects persisted, and that communication from the roofing company ceased in early 2024. As a result, he filed a lawsuit in Etowah County, Alabama, alleging breach of express and implied warranties, as well as negligent or wanton installation and repair, and sought damages.The roofing company moved to dismiss the lawsuit for improper venue, arguing that a forum-selection clause in a “Service Agreement” required all disputes to be heard in Madison County, Alabama. The company attached an unsigned and undated sample agreement to its motion, but did not produce a copy signed by the homeowner or any evidence that the homeowner had agreed to such a clause. The homeowner responded that he had never signed, nor was he aware of, the agreement submitted by the company and also challenged the clause’s reasonableness. The Etowah Circuit Court denied the company’s motion to dismiss for improper venue.The Supreme Court of Alabama reviewed the company’s petition for a writ of mandamus, which sought to compel the lower court to dismiss the case or transfer it to Madison County. The Supreme Court held that the company failed to meet its burden of proving that the forum-selection clause applied, as it did not present evidence linking the blank agreement to the parties’ actual contract. Therefore, the Supreme Court of Alabama denied the petition, concluding that the circuit court did not clearly err in refusing to dismiss or transfer the case. View "Ex parte Continental Roofing Company, LLC" on Justia Law