Justia Alabama Supreme Court Opinion Summaries

Energy Alabama, an advocacy group, sought to intervene in an administrative docket maintained by the Alabama Public Service Commission. The docket concerned the formula used to adjust rates that Alabama Power Company charges its customers, specifically the Rate Energy Cost Recovery (“Rate ECR”) mechanism. Energy Alabama argued that ongoing activities in the docket, including the monthly filings and interim consent orders adjusting the ECR Factor, warranted its intervention to advocate for fair and equitable electricity pricing.After Energy Alabama filed its petition to intervene in April 2024, the Commission denied the request, finding there was no pending “proceeding” in the administrative docket that would allow intervention under the applicable statutes and commission rules. Energy Alabama sought rehearing, which was also denied. Energy Alabama then appealed to the Montgomery Circuit Court, which permitted Alabama Power to intervene in support of the Commission. The Montgomery Circuit Court affirmed the Commission’s denial of intervention, concluding that Energy Alabama lacked a statutory basis to intervene absent an open proceeding.The Supreme Court of Alabama reviewed the case on appeal. It held that Energy Alabama was not entitled to intervene because the statutes governing the Commission provide intervention rights only in specified “proceedings,” such as those initiated for rate changes or complaints regarding utility practices. The Court found that the ongoing administrative activities in the docket did not constitute such a proceeding, nor did the entry of interim consent orders reopen prior completed proceedings. The Supreme Court of Alabama affirmed the circuit court’s judgment, concluding that Energy Alabama’s chosen path for intervention was foreclosed by the relevant statutes and Commission rules. View "Energy Alabama v. Alabama Public Service Commission" on Justia Law

A marine-equipment dealership purchased insurance policies through its agent, who obtained those policies from a wholesale insurance broker. The dealership alleged it paid its insurance agent a sum significantly greater than the premiums that were ultimately forwarded to the broker and that, after canceling the policies, the agent failed to return the excess amount. The broker refunded a portion of the unearned premiums to the agent, but the dealership maintained that it was also owed the larger sum it paid in excess, as those funds had not been properly applied or returned.The dealership filed suit in the Baldwin Circuit Court against the insurance agent, alleging negligence, wantonness, recklessness, and/or fraud for mishandling and wrongfully retaining premium payments. The insurance agent, in response, moved to interplead the smaller, refunded amount from the broker into court in exchange for its dismissal from the case. The circuit court granted the agent’s motions to interplead those funds, awarded attorney’s fees to the agent from that amount, and dismissed the agent from the action. The dealership’s motion for reconsideration was denied, and subsequently, the dealership and the wholesale broker petitioned for relief.The Supreme Court of Alabama reviewed the petition for a writ of mandamus. It held that interpleader was not proper in this situation because the funds at issue were not exposed to double or multiple liability, and the claims against the agent included independent allegations of liability beyond the interpleaded sum. The court determined that the trial court erred in dismissing the agent from the lawsuit based solely on the interpleader. The Supreme Court of Alabama granted the petition and issued the writ, directing the circuit court to vacate its order. View "In re: Gulf Shores Power Sports, Inc. v. McCarron Insurance Group, Inc." on Justia Law

A group of plaintiffs filed suit in the Montgomery Circuit Court against the Secretary of the Alabama Department of Workforce, alleging that their applications for unemployment benefits during the COVID-19 pandemic were unreasonably delayed. They also claimed that the Department’s notices regarding the unemployment process were too difficult to understand, violating the due process requirements of the Fourteenth Amendment and the Social Security Act. Their complaint sought various forms of injunctive relief, primarily to require prompt processing of applications and to mandate that notices be written at a level comprehensible to people with an eighth-grade education.The Montgomery Circuit Court dismissed the complaint, holding that it lacked subject-matter jurisdiction because the plaintiffs had not exhausted the required state administrative remedies under Alabama law. The Supreme Court of Alabama affirmed, rejecting the plaintiffs’ argument that federal law under Patsy v. Board of Regents of the State of Florida precluded the exhaustion requirement for claims brought under 42 U.S.C. § 1983. The United States Supreme Court subsequently reversed this decision, but only on the narrow ground that, when a state’s exhaustion requirement effectively immunizes state officials from § 1983 claims of administrative delay, such claims cannot be denied for failure to exhaust. The case was remanded for further proceedings.On remand, the Supreme Court of Alabama directed the circuit court to determine if the case was moot, given that the Secretary asserted all plaintiffs had either been paid or received final denials. The circuit court found the case moot. Reviewing this determination, the Supreme Court of Alabama held that the plaintiffs had not shown any remaining justiciable controversy, as their delay claims were moot and their arguments for relief on the notice claims were inadequately supported. The court dismissed the appeal as moot. View "Johnson v. Reed" on Justia Law

This dispute arose from a series of business dealings among several corporate parties involved in the repurposing of ammonium nitrate water from a landfill in Mobile County, Alabama. The plaintiffs, two corporate entities, accused certain defendants of disrupting long-standing contracts and business relationships by sharing confidential information in violation of a 2013 contract. The alleged conduct resulted in the plaintiffs being cut out of relationships they had developed over many years. The 2013 contract at issue contained a forum-selection clause requiring that disputes be brought exclusively in courts located in New York, New York.After the plaintiffs initiated suit in the Monroe Circuit Court, the defendants sought dismissal for improper venue, citing the forum-selection clause and arguing in the alternative that, even if venue were proper in Alabama, it was not proper in Monroe County. The defendants also asserted that the plaintiffs’ tort claims failed to state a claim. While these motions were pending, disputes arose over the scope and timing of discovery. The trial court issued a series of discovery-related orders, culminating in a January 6, 2026, order requiring the defendants to provide broad discovery, including depositions and responses to interrogatories, before the motion to dismiss would be heard.The Supreme Court of Alabama granted the defendants’ petition for a writ of mandamus. The Court held that venue is a threshold issue that should be addressed as soon as practicable and that the trial court exceeded its discretion by requiring the defendants to participate in extensive merits-based discovery before ruling on the venue motion. The Court directed the trial court to vacate its January discovery order and to rule expeditiously on the motion to dismiss. Pending that ruling, any discovery must be limited to issues relevant to venue. View "In re: Southern Logistics, Inc. v. UOP, LLC" on Justia Law

An inmate at Easterling Correctional Facility filed a lawsuit against his former wife and two employees of the Alabama Department of Corrections. He alleged that his ex-wife falsely told one of the employees, an agent, that he had hired someone to kill her. He further claimed that the agent failed to exercise due diligence and then falsely imprisoned him in a segregation unit without due process. The inmate also alleged that a correctional officer defamed, libeled, and slandered him, and denied him access to the courts by refusing to notarize a petition he attempted to file. He asserted similar claims of defamation against his former wife.The employees sought to transfer venue from the Barbour Circuit Court to the Montgomery Circuit Court, arguing that the complaint was essentially a petition for a writ of certiorari. The Barbour Circuit Court granted the transfer. The employees then moved for summary judgment in the Montgomery Circuit Court. Five days after the motion was filed, the Montgomery Circuit Court granted summary judgment for the defendants. The inmate filed for an extension of time to respond and later sought to alter or vacate the judgment, explaining that he had not received the motion until after the court had already ruled. The Montgomery Circuit Court denied these motions.The Supreme Court of Alabama reviewed the case. It determined that the Montgomery Circuit Court erred by granting summary judgment before the inmate received the motion and without providing him a meaningful opportunity to respond, as required by Rule 56 of the Alabama Rules of Civil Procedure. The Supreme Court of Alabama reversed the summary judgment and remanded the case for further proceedings, holding that the lower court’s failure to provide notice or an opportunity to respond prejudiced the inmate and violated procedural safeguards. View "McConico v. Haynes" on Justia Law

A landlord and a tenant, a ballet studio, entered into two lease agreements for suites in a shopping center. The leases contained provisions for indemnification, default, and attorney fees. After the ballet studio vacated the premises, alleging that the landlord failed to address mold issues that caused personal injuries to two individuals associated with the studio and damage to the studio’s property, the studio and the individuals filed a multi-count complaint against the landlord. The landlord counterclaimed for unpaid rent and sought defense and indemnity from the ballet studio for the claims made by the individuals.The Montgomery Circuit Court addressed a partial summary judgment motion filed by the landlord, which concerned only the claims between the landlord and the ballet studio, not the individuals’ personal injury claims. The ballet studio and the individuals filed a response to the summary judgment motion, but it was submitted one business day late. The trial court granted the landlord’s motion to strike the late response and, later, denied the plaintiffs’ attempt to resubmit the same response. The court then entered a partial summary judgment in favor of the landlord. Subsequently, the court certified this partial summary judgment as final under Rule 54(b), Alabama Rules of Civil Procedure, but also included language purporting to dismiss the entire case.On appeal, the Supreme Court of Alabama affirmed the trial court’s orders striking the untimely response and denying its resubmission, holding that the trial court did not abuse its discretion. The Supreme Court also affirmed the certification of the partial summary judgment as final but reversed the dismissal of the entire case, noting that claims by the individuals against the landlord and the determination of damages owed to the landlord remained unresolved. The case was remanded for further proceedings. View "Commercial Properties, Inc. v. Charalambidou" on Justia Law

A police officer in Decatur, Alabama, was involved in a fatal shooting that occurred while a tow-truck driver attempted to repossess a vehicle from a homeowner’s property. The tow-truck driver had experienced a prior confrontation with the homeowner, who allegedly pointed a gun at him and ordered him to leave. When the tow-truck driver returned with several police officers prepositioned for safety, the homeowner again emerged armed and pointed his gun, first at the tow-truck driver and then in the direction of one of the officers. The officer fired, resulting in the homeowner’s death.After being indicted for murder, the officer moved for pretrial dismissal, claiming statutory immunity under Alabama’s defense-of-persons statute, which justifies the use of force under certain conditions and provides for immunity from prosecution if the statute’s requirements are met. The Morgan Circuit Court held a pretrial hearing but denied the motion, reasoning that the peace-officer-specific use-of-force statute was the applicable law rather than the more general defense-of-persons statute. The court focused on whether the officer acted as a “reasonable police officer” and whether he was acting within the scope of his police authority, ultimately setting the case for trial but staying proceedings pending appellate review. The Alabama Court of Criminal Appeals affirmed this approach, also applying the peace-officer statute.The Supreme Court of Alabama reviewed the case and determined that the lower courts had applied the incorrect legal standard by relying on the peace-officer statute instead of the defense-of-persons statute. The Supreme Court held that the officer had a clear legal right to have his immunity claim evaluated under the defense-of-persons statute, which applies to all persons, not just police officers, and provides for pretrial immunity. The Court issued a writ of mandamus, directing the circuit court to vacate its previous order and reevaluate the officer’s claim under the correct statute. View "In re: State of Alabama v. Marquette" on Justia Law

The appellant, an inmate in the Alabama Department of Corrections, pleaded guilty in 2008 to two counts of reckless murder and one count of assault related to a fatal car accident he caused while under the influence of methamphetamine. He was sentenced to concurrent prison terms. Over subsequent years, he submitted requests to the Department of Corrections and its Commissioner for temporary leave, specifically Christmas furloughs, and applied multiple times for early parole consideration, which were denied due to disciplinary infractions and other reasons. He also requested access to his parole file, entry into the Supervised Reentry Program, a nondriver identification card, and mental-health treatment, alleging violations of state and federal law. His efforts to seek accountability included letters to officials and bar complaints, which were not acted upon.He filed a pro se complaint in the Montgomery Circuit Court against various state officials and agencies, asserting claims related to the denial of parole, furloughs, access to records, program participation, identification, and mental-health care. The State officials and Board officials moved to dismiss, arguing lack of standing, failure to state a claim, and proper application of law. The circuit court granted both motions to dismiss, with prejudice, finding no improper conduct or grounds for relief.The Supreme Court of Alabama reviewed the appeal and determined that the claims against the State, its agencies, and entities were barred by absolute immunity under the Alabama Constitution. Furthermore, it held that the proper avenue for challenging Board or Department actions was through a petition for a common-law writ of certiorari, not a declaratory-judgment action, and that appellate jurisdiction over such matters belonged to the Court of Criminal Appeals, not the Supreme Court. Consequently, the Supreme Court of Alabama dismissed the appeal. View "Phillips v. Ivey" on Justia Law

A police officer employed by the Birmingham Police Department was patrolling late at night during a rainfall when his patrol car struck a pedestrian, resulting in the pedestrian’s death. The pedestrian was walking along a roadway, wearing dark clothing, and was found to be intoxicated. At the time of the accident, the officer was listening to a podcast on his personal cell phone, which was resting on the passenger seat; he stated he did not see the pedestrian before the collision. There was conflicting evidence as to whether the officer was exceeding the posted speed limit.The decedent’s estate brought a wrongful-death action against the officer in his official and individual capacities, as well as against the City of Birmingham based on vicarious liability. The officer and the city moved for summary judgment, arguing that both were entitled to immunity. The Jefferson Circuit Court granted summary judgment on the official-capacity claim based on State immunity but denied summary judgment on the individual-capacity and city claims, finding that there was substantial evidence the officer had acted beyond his authority by using his personal cell phone while driving, possibly violating department rules.The Supreme Court of Alabama reviewed the case on a petition for writ of mandamus, which is permissible when immunity is at issue. The Alabama Supreme Court concluded that patrolling is a discretionary function covered by State-agent immunity under the fourth category of Ex parte Cranman and § 6-5-338(a), Ala. Code 1975. The Court held that the officer did not exceed his authority by listening to a podcast, as this did not violate department rules, and found that even if the officer was speeding, such conduct would not remove his immunity in these circumstances. The Court therefore ordered summary judgment for both the officer and the city. View "In re: Cuin v. The City of Birmingham" on Justia Law

A pharmacy, operated by a licensed pharmacist, improperly compounded a prescription medication for a patient after a technician mistakenly entered a formula with the wrong dosage. The patient consumed the medication, suffered severe poisoning, required intensive medical treatment, and subsequently filed suit against the pharmacy and the pharmacist. She alleged negligence, wantonness, product liability, breach of the Alabama Extended Manufacturer’s Liability Doctrine, breach of implied warranty of merchantability, and failure to warn. The pharmacy’s liability insurer, Nationwide, declined coverage, citing a professional-services exclusion in its policy. The pharmacy had previously been covered by a different insurer, Zurich, whose policy did not exclude such claims.After the patient obtained a substantial judgment against the pharmacy, a separate action was brought to determine whether the Nationwide policy covered the claim and whether the insurance agents who procured the policy for the pharmacy had been negligent or wanton in failing to secure proper coverage. The Tuscaloosa Circuit Court entered summary judgment for Nationwide, finding the professional-services exclusion applied, and for the insurance agents, concluding the pharmacy was contributorily negligent for not reading its policy.The Supreme Court of Alabama reviewed the case. It held that the professional-services exclusion in the Nationwide policy unambiguously barred coverage for all claims, including product-liability claims, arising from the compounding of medication, which is a professional service under Alabama law. The Supreme Court also held that the pharmacy was contributorily negligent as a matter of law for failing to read its insurance policy, which expressly excluded the type of coverage in question, thereby precluding any claim for negligent failure to procure insurance. The summary judgments in favor of Nationwide and the agency defendants were affirmed. View "OMS Pharmacy, Inc. v. Nationwide Property and Casualty Insurance Company" on Justia Law