Justia Alabama Supreme Court Opinion Summaries

The case involves members of the Auburn University Board of Trustees and various Auburn University employees (defendants) who were sued by Patti Northcutt and her husband, Walter Northcutt (plaintiffs). Patti, a former employee and doctoral student at Auburn, alleged that the defendants retaliated against her for previous lawsuits and grievances she had filed, which were settled through agreements. She claimed that the defendants breached these settlement agreements and interfered with her ability to complete her doctoral program and obtain employment at Auburn.The plaintiffs initially filed their complaint in the Lee Circuit Court, which they amended multiple times. The third amended complaint included claims under the Family Medical Leave Act (FMLA), 42 U.S.C. § 1983 for First Amendment retaliation, equal protection, and procedural due process violations, as well as state-law claims for breach of contract, intentional interference with contractual relations, and intentional infliction of emotional distress. The defendants moved to dismiss these claims, asserting federal qualified immunity and State immunity under the Alabama Constitution.The Lee Circuit Court granted the motion to dismiss the First Amendment and intentional infliction of emotional distress claims but denied the motion regarding the other claims. The defendants then petitioned the Supreme Court of Alabama for a writ of mandamus to direct the trial court to dismiss the remaining claims.The Supreme Court of Alabama granted the petition in part, directing the trial court to dismiss the claims for monetary damages against the employee defendants in their individual capacities under § 1983 for equal protection and procedural due process violations, based on federal qualified immunity. The Court also directed the dismissal of the plaintiffs' request for attorneys' fees related to state-law claims for prospective injunctive relief, based on State immunity. However, the Court denied the petition regarding the plaintiffs' request for attorneys' fees related to federal-law claims for prospective injunctive relief and the state-law claims for monetary damages against the employee defendants in their individual capacities. View "Ex parte B.T. Roberts" on Justia Law

Faya Rose Toure sued the City of Selma, Chief of Police Spencer Collier, and police officer Devon McGuire following her arrest for fourth-degree theft of property and attempting to elude. Toure claimed McGuire and Collier committed assault and battery, false arrest, unlawful imprisonment, invasion of privacy, negligence, wantonness, abuse of legal process, unreasonable seizure, and defamation/libel. She also accused the City of negligent hiring, training, and supervision, and fostering a custom of police abuse. Toure sought $1,000,000 in compensatory damages and $3,000,000 in punitive damages.The defendants filed for summary judgment, citing peace-officer and State-agent immunity. They provided evidence including deposition testimonies, incident reports, and body camera footage showing McGuire witnessed Toure removing a campaign sign and subsequently attempting to elude him. Toure argued she removed the sign believing it was illegally placed and felt intimidated by McGuire, who was in an unmarked vehicle. The trial court granted summary judgment for the City but denied it for McGuire and Collier.The Supreme Court of Alabama reviewed the case. It found that McGuire and Collier were performing discretionary functions within their law enforcement duties, entitling them to immunity. The court determined that McGuire had at least arguable probable cause for Toure's arrest, and Toure failed to provide substantial evidence that McGuire or Collier acted willfully, maliciously, or beyond their authority. Consequently, the court held that McGuire and Collier were entitled to peace-officer and State-agent immunity and directed the trial court to enter summary judgment in their favor. The petition for a writ of mandamus was granted, and the writ was issued. View "Ex parte McGuire" on Justia Law

Nathan Nash was involved in an automobile collision in Tuscaloosa County with a truck driven by Joshua Hunter Jones and owned by Davis Ice Cream Alabama, LLC. Nash filed a complaint in Jefferson County against Jones for negligence and wantonness, and against Davis Ice Cream for negligent training and hiring. Nash and Jones reside in counties adjacent to Jefferson County, and Davis Ice Cream's principal place of business is in Jefferson County. Nash received medical treatment and had an employer in Jefferson County.The Jefferson Circuit Court transferred the case to the Tuscaloosa Circuit Court based on a motion by Davis Ice Cream, citing Alabama's forum non conveniens statute. Nash objected, highlighting his medical treatment and employer connections in Jefferson County. After the transfer order, Nash filed a motion for reconsideration and then petitioned the Supreme Court of Alabama for a writ of mandamus.The Supreme Court of Alabama reviewed the case and determined that the Jefferson Circuit Court exceeded its discretion in transferring the case. The Court noted that Davis Ice Cream's principal place of business and Nash's medical providers and employer were in Jefferson County, establishing a strong connection to the action. In contrast, Tuscaloosa County's only connection was the location of the collision. The Court concluded that Davis Ice Cream failed to demonstrate that Tuscaloosa County had a strong connection to the action and that Jefferson County had a weak connection. Therefore, the Supreme Court of Alabama granted Nash's petition for a writ of mandamus and directed the Jefferson Circuit Court to vacate its order transferring the case to the Tuscaloosa Circuit Court. View "Ex parte Nash" on Justia Law

Timothy Brian Johnson and Phillip Barnes, nephews of the deceased Samuel D. Johnson, appealed a judgment from the Lamar Circuit Court. The court declared that Alabama's antilapse statute, § 43-8-224, Ala. Code 1975, did not apply to Johnson's will, making Judith Mayers the sole beneficiary. Johnson's will, executed in October 1990, left his entire estate to his father, Coy D. Johnson. If Coy predeceased him, the estate would be divided equally among his siblings, Roger D. Johnson, Denny R. Johnson, Judith A. Mayers, and Janice M. Barnes. If none of these individuals survived him, the estate would pass to his nearest living heirs. At Johnson's death in July 2022, Mayers was the only surviving named beneficiary.The Lamar Probate Court admitted the will to probate and issued letters of administration to Mayers. The administration was then moved to the Lamar Circuit Court. Mayers petitioned the circuit court to declare that the antilapse statute did not apply, asserting she was the sole beneficiary. The circuit court agreed, finding the will unambiguous and ruling that the antilapse statute did not apply, making Mayers the sole beneficiary.The Supreme Court of Alabama reviewed the case de novo. The court held that the antilapse statute, which prevents a devise from lapsing if a beneficiary predeceases the testator, did not apply because the will included survivorship language and an alternative devise provision. The will clearly indicated that only the named beneficiaries who survived the testator would inherit, and if none survived, the estate would pass to the nearest living heirs. Since Mayers was the only surviving named beneficiary, she was entitled to the entire estate. The Supreme Court of Alabama affirmed the circuit court's judgment. View "Johnson v. Mayers" on Justia Law

Edward Conant Gartrell, Jr. and Sharon Smith Gartrell were divorced by a 2023 judgment of the Madison Circuit Court, which denied Sharon's request for periodic alimony. Sharon appealed to the Court of Civil Appeals, arguing that the trial court erred in denying her alimony request. The Court of Civil Appeals affirmed the divorce judgment in part but reversed the denial of periodic alimony, remanding the case for reconsideration under § 30-2-57. On remand, the trial court again denied Sharon's request for periodic alimony, finding she failed to prove her need and the husband's ability to pay without undue hardship.Sharon appealed again, arguing the trial court erred by not reserving jurisdiction to award periodic alimony in the future. The Court of Civil Appeals, in a plurality opinion, affirmed the denial of periodic alimony but agreed that the trial court should have reserved jurisdiction, citing the potential for Sharon's financial circumstances to change. The dissenting opinion argued that § 30-2-57(c) provides the only circumstances under which a court can reserve jurisdiction, implying that the common law allowing broader discretion had been abrogated.The Supreme Court of Alabama reviewed the case to address whether § 30-2-57(c) limits the circumstances in which a trial court can reserve jurisdiction to award periodic alimony. The court held that § 30-2-57(c) does not provide the only circumstances for reserving jurisdiction. Instead, it requires reservation in specific circumstances but does not preclude the court's common-law authority to reserve jurisdiction when justice requires it. The court affirmed the Court of Civil Appeals' judgment, allowing the trial court to reserve jurisdiction to award periodic alimony in the future if warranted by changing circumstances. View "Ex parte Gartrell" on Justia Law

Michael Straus wired $60,000 to an account at GBC International Bank (GBC) owned by Apex Oil and Gas Trading, LLC (Apex). Apex allegedly failed to provide the services Straus paid for, withdrew the funds, and disappeared. Straus sued GBC in May 2024, claiming negligence and wantonness, alleging GBC closed Apex's account knowing Apex was engaged in fraud. Straus argued GBC's website acknowledged its obligations under the Patriot Act to prevent such fraud.The Jefferson Circuit Court denied GBC's motion to dismiss for lack of personal jurisdiction. GBC then petitioned the Supreme Court of Alabama for a writ of mandamus to direct the circuit court to dismiss the case.The Supreme Court of Alabama reviewed the case de novo. GBC argued it had no general or specific personal jurisdiction in Alabama, supported by an affidavit from its executive vice president and chief financial officer, Richard Holmes. Holmes stated GBC had no business operations, property, or targeted advertising in Alabama. Straus's response included an unsworn declaration, which the court found insufficient to establish jurisdiction.The Supreme Court of Alabama held that Straus's unilateral action of wiring money to GBC did not establish specific personal jurisdiction. GBC's general statements on its website about compliance with federal law did not constitute purposeful availment of conducting activities in Alabama. The court concluded that GBC did not have the minimum contacts necessary to subject it to personal jurisdiction in Alabama. Therefore, the court granted GBC's petition and directed the circuit court to dismiss Straus's complaint. View "Ex parte GBC International Bank" on Justia Law

Eric Jackson, a commercial tractor-trailer driver, was injured in a motor-vehicle collision in Morgan County, Alabama, on December 20, 2020. Jackson's personal vehicles were insured by State Farm Mutual Automobile Insurance Company under policies issued in Kentucky, which included uninsured/underinsured-motorist (UIM) coverage. In April 2022, Jackson sued the alleged at-fault driver in the Morgan Circuit Court. Later, he sought to amend his complaint to add State Farm as a defendant to recover UIM benefits. State Farm denied the claim, asserting that Jackson failed to file his UIM claim within the two-year period required by Kentucky law, as stipulated in the insurance policies.The Morgan Circuit Court granted State Farm's motion for judgment on the pleadings, concluding that Kentucky law governed the claim and that Jackson did not file his complaint within the required two-year period. Jackson appealed, arguing that Alabama's six-year statute of limitations should apply and that any contractual provision shortening this period was void under Alabama law.The Supreme Court of Alabama reviewed the case de novo. The court noted that Alabama enforces choice-of-law provisions in contracts unless they violate public policy. Jackson's policies explicitly incorporated Kentucky's two-year statute of limitations for filing accident-related tort claims. The court found that the policies were clear and unambiguous in this regard and that Kentucky law, which allows such contractual limitations, applied. The court distinguished this case from others where no specific choice-of-law provision was present or where the provision did not explicitly include procedural laws like statutes of limitations.The Supreme Court of Alabama affirmed the lower court's judgment, holding that the contractual provision incorporating Kentucky's two-year statute of limitations was valid and enforceable, thus barring Jackson's UIM claim. View "Jackson v. State Farm Mutual Automobile Insurance Co." on Justia Law

Walter F. Scott III filed an appeal against the Alabama Department of Revenue, challenging the Jefferson County Board of Equalization's valuation of 176 parcels of real property for property-tax purposes. Scott identified himself as "Agent for Owners" in his notice of appeal. The Department, Jefferson County, and the Board moved to dismiss Scott's appeal, arguing that he had incorrectly filed the tax appeal and had not paid the necessary filing fees.The Jefferson Circuit Court granted the motion to dismiss, reasoning that Scott was improperly attempting to aggregate 176 separate and distinct parcels of property into one lawsuit for the purpose of appealing tax assessments on each parcel. The court concluded that each parcel required a separately filed lawsuit accompanied by the appropriate filing fees. Scott then appealed the judgment of dismissal to the Supreme Court of Alabama.The Supreme Court of Alabama reviewed the case de novo and concluded that the circuit court erred in dismissing the tax appeal. The court held that the relevant statutes, §§ 40-3-24 and 40-3-25, Ala. Code 1975, do not require a taxpayer to appeal each assessment separately. The court found that the language of the statutes allows for multiple contested assessments to be included in a single appeal to the circuit court. The court also noted that consolidating challenges to multiple parcels into one appeal is consistent with the liberal joinder allowed by the Alabama Rules of Civil Procedure.The Supreme Court of Alabama reversed the circuit court's judgment and remanded the case for further proceedings consistent with its opinion. The court did not address whether multiple owners could use a single appeal to contest the assessments of multiple parcels, as this issue had not been sufficiently explored at this point in the action. View "Scott v. Alabama Department of Revenue" on Justia Law

EBSCO Industries, Inc. owned a 5.5-acre parcel of land in Tuscaloosa County, which it leased to Michael R. Ballard for hunting purposes starting in 1990. The lease was renewed annually until February 2022. Ballard purchased adjacent property in 1992 and believed a partial fence marked the boundary between his property and EBSCO's. In 2016, a survey confirmed the boundary, and in 2021, Ballard began constructing a hog farm on the disputed parcel. EBSCO sent cease-and-desist letters, but Ballard claimed ownership through adverse possession.The Tuscaloosa Circuit Court found that EBSCO held legal title to the disputed parcel but ruled that Ballard and his entities had acquired ownership through adverse possession by 2012. The court based its decision on Ballard's actions, such as contracting with Alabama Power Company, harvesting trees, and replacing a gate without providing EBSCO a key. EBSCO's post-judgment motion to alter, amend, or vacate the judgment was denied, leading to this appeal.The Supreme Court of Alabama reviewed the case and determined that the trial court erred in its finding. The court noted that Ballard's use of the land was permissive under the lease, which could not ripen into adverse possession until the lease ended in February 2022. Since Ballard performed no acts on the disputed parcel after the lease ended, the trial court's finding of adverse possession as early as 2012 was incorrect. The Supreme Court reversed the trial court's judgment and remanded the case for further proceedings consistent with its opinion. View "EBSCO Industries, Inc. v. Ballard" on Justia Law

Joy Goodwin Adams sued Tiffany Rudd Atkinson, Katherine M. Rudd, Goodwin Capital Partners, Ltd., and KATISAM, Inc., seeking reimbursement for attorneys' fees she paid to a third party. The Jefferson Circuit Court dismissed her suit with prejudice, leading Joy to appeal. The central issue was whether the terms "hold harmless" and "indemnify" are synonymous when used independently in a contract. The Supreme Court of Alabama held that they are synonymous.The case involves three trusts and two agreements. Joy's parents created two trusts in 1986 and 1987 for Joy and her daughters, Tiffany and Kate. Joy created a third trust in 1989. Joy executed a 2011 release-and-indemnification agreement with BB&T, a co-trustee, and a 2013 settlement agreement with the defendants after Tiffany and Kate sued her for alleged breaches of fiduciary duties. The 2013 agreement included a "hold harmless" provision requiring the defendants to protect Joy against claims for attorneys' fees by corporate trustees successfully defending against suits initiated by Tiffany and Kate.In prior litigation, Tiffany and Kate sued BB&T for negligence, and BB&T filed a third-party claim against Joy for attorneys' fees. The federal district court granted summary judgment in favor of BB&T on the negligence claim and denied Joy's motion on the indemnification claim. Joy settled BB&T's claim for $614,791.62 and then demanded reimbursement from the defendants, who refused.The Supreme Court of Alabama reviewed the case de novo and concluded that "hold harmless" and "indemnify" are synonymous, meaning the defendants agreed to reimburse Joy for the attorneys' fees she paid to BB&T. The court reversed the circuit court's judgment and remanded the case for further proceedings. View "Adams v. Atkinson" on Justia Law