Justia Alabama Supreme Court Opinion Summaries

The plaintiff alleged that since 2018, stormwater runoff from a drainage easement in a residential subdivision caused damage to his property. He first sued the homeowners’ association and the four owners of lots nearest his property, resulting in a jury verdict against the association and pro tanto settlements with three lot owners. After continued drainage issues and difficulties collecting the judgment, the plaintiff brought a new suit in 2024 against the homeowners’ association, a newly formed association, all 21 lot owners, and the boards of both associations. The central claim against the lot owners was their alleged undivided interest in the common property, including the drainage easement.In the Mobile Circuit Court, most non-board-member lot owners moved to dismiss the claims against them, arguing they did not own the drainage easement and had no involvement in causing the drainage problem. Two lot owners, Wallace and Smith, additionally asserted that prior settlement agreements barred further claims against them. The circuit court granted the motions to dismiss the non-board-member lot owners and enforced Wallace’s and Smith’s releases. Claims against the homeowners’ association and the six board members remained pending. The court certified its dismissal orders as final under Rule 54(b), allowing the plaintiff to appeal.The Supreme Court of Alabama reviewed whether the circuit court’s Rule 54(b) certification was proper. Applying a de novo standard to the question of finality and reviewing for excess of discretion, the Court concluded the certification was improper. The Court found the dismissed claims and those still pending were too closely intertwined, and the possibility that the remaining claims could moot the need for appellate review weighed against certification. Accordingly, the Supreme Court of Alabama dismissed the appeal for lack of a final judgment and did not reach the merits. View "Carpenter v. Jacobs" on Justia Law

A rental company, Pharming Capital, became involved in a dispute after a portable cabin was delivered to land in Geneva County, Alabama, under a rent-to-own contract with a third party, Leland Hedlund. Although the contract documents inconsistently listed addresses in both Florida and Alabama, the cabin was ultimately placed on property owned by James R. Turner. Turner had agreed to sell this property to James Gough in 2021, but the final deed conveying ownership to Gough and his wife was not recorded until July 22, 2024, after the events in question. When repossession of the cabin was attempted due to nonpayment, access was prevented by a locked gate. Pharming Capital, relying on property searches and public records, believed Turner was the record owner and sued him for possession of the building.The Coffee Circuit Court (trial court) first granted summary judgment in favor of Pharming Capital regarding some of Turner's counterclaims, but allowed negligence/wantonness and punitive damages claims to proceed to trial. After a jury trial, Turner was awarded compensatory and punitive damages. Pharming Capital moved for judgment as a matter of law and a new trial, which were denied. Pharming Capital then appealed.The Supreme Court of Alabama reviewed the case and determined that the trial court committed reversible error by allowing a copy of the complaint filed by Pharming Capital to be taken into the jury room, contrary to Rule 51 of the Alabama Rules of Civil Procedure, which prohibits pleadings from being sent to the jury room. The Supreme Court of Alabama reversed the trial court’s judgment and remanded the case for further proceedings consistent with its opinion. The Court did not reach or resolve other arguments raised on appeal, as the error regarding the complaint was dispositive. View "Pharming Capital, LLC v. Turner" on Justia Law

A woman, acting as personal representative of her late husband's estate, brought a medical negligence action after her husband died following treatment at the University of South Alabama Hospital. She alleged that various doctors and U.S.A. Healthcare Management, LLC (HCM) failed to provide adequate care, leading to his death. HCM employed the hospital staff involved and was created by the University of South Alabama (USA) to manage its healthcare system. The plaintiff claimed HCM was vicariously liable for the doctors’ alleged negligence.HCM moved for dismissal or summary judgment in the Mobile Circuit Court, arguing it was entitled to State immunity based on its relationship to USA, a State institution. HCM presented affidavits and documentation showing USA was its sole member and manager, and that HCM’s finances were intertwined with USA. The plaintiff opposed, arguing HCM was a separately created LLC under Alabama law, formed to shield USA from certain liabilities, and operated as an independent entity. The circuit court granted summary judgment in favor of HCM, finding it was entitled to immunity, and later certified the judgment as final for appeal.The Supreme Court of Alabama reviewed the case de novo. It examined whether HCM, as an LLC created by a State agency, qualified as a State agency for purposes of immunity under Article I, § 14, of the Alabama Constitution. Applying the factors from Armory Commission of Alabama v. Staudt, the court determined HCM’s powers and functions were typical of private entities, not unique to government, and its relationship with USA did not override its separate legal status as an LLC. The court held HCM was not entitled to State immunity and reversed the circuit court’s summary judgment, remanding the case for further proceedings. View "Marsh v. U.S.A. Healthcare Management, LLC" on Justia Law

Cadence Bank hired a law firm in October 2020 to provide legal services related to an $8 million loan to a holding company, with the loan closing in November 2020. The collateral for the loan included assets of a subsidiary insurer, which operated in Louisiana. Following severe hurricane damage in August 2021, the Louisiana Insurance Commissioner (LIC) moved to place the insurer into receivership, contesting the validity and priority of Cadence’s security interest in the insurer’s assets due to a lack of required regulatory approval for the loan. By March 2022, Cadence was aware of the LIC’s position disputing the validity of its security interest.The Jefferson Circuit Court denied the law firm’s motion to dismiss or for summary judgment in Cadence's legal-malpractice lawsuit, which alleged the firm should have advised Cadence to seek regulatory approval for the loan and later added a claim of fraudulent suppression regarding the attorneys’ expertise. The trial court certified questions regarding whether Cadence’s claims were time-barred under the Alabama Legal Services Liability Act (ALSLA), and whether any tolling or ameliorative provision would save the claims.The Supreme Court of Alabama held that, under the plain language of the ALSLA, the statute of limitations for a legal-malpractice claim begins to run when the act or omission giving rise to the claim occurs—the “occurrence” rule—rather than when the client suffers actual damage. The Court found that the relevant act or omission occurred no later than the November 2020 loan closing, and Cadence’s knowledge of the facts within the two-year limitations period barred application of any six-month ameliorative period. The Court also found Cadence’s fraud-based claim insufficiently pleaded to invoke tolling under § 6-2-3. Accordingly, the Supreme Court of Alabama reversed the trial court’s judgment and directed it to enter judgment for the defendant law firm. View "Nexsen, PC v. Cadence Bank" on Justia Law

A 20-year-old college student, while on spring break in Alabama, purchased alcohol from a Walmart store using a fake Georgia driver’s license that falsely indicated he was of legal age. A Walmart cashier checked the ID for a few seconds before approving the sale. The following day, after consuming several alcoholic beverages purchased from Walmart, the student drove under the influence and struck and killed an 80-year-old man, James Reed, who was riding a mobility scooter. Reed’s wife, Bonnie Estell, witnessed the accident. The student later admitted that his intoxication, caused by the alcohol bought at Walmart, played a role in the fatal incident.Reed’s widow, appointed by an Indiana court as special administrator of his estate for the purpose of pursuing wrongful death damages, brought a lawsuit against Walmart in the Baldwin Circuit Court. She asserted claims under Alabama’s Dram Shop Act, seeking damages for Reed’s death. Claims against the student driver were settled and dismissed, leaving Walmart as the sole defendant. The trial court denied Walmart’s motions for summary judgment and judgment as a matter of law, allowing the Dram Shop Act claim to proceed to a jury. The jury awarded $900,000 in compensatory damages against Walmart.The Supreme Court of Alabama reviewed the Baldwin Circuit Court’s denial of Walmart’s postjudgment motion for judgment as a matter of law. The Court held that the Dram Shop Act allows for a claim for death, expressly overruling prior precedent to the contrary. The Court further found that Estell’s appointment as special administrator was sufficient to assert such a claim, and that a jury question existed as to whether Walmart violated the law in selling alcohol to a minor. The Supreme Court of Alabama affirmed the trial court’s judgment. View "Walmart, Inc. v. Estell" on Justia Law

The dispute centers on a commercial contract between two companies, one providing live-chat and visitor-monitoring software services and the other purchasing licenses for these services. The contract, first executed in 2008 and amended multiple times, included automatic annual renewal, a termination-for-convenience clause, and a late-payment-charge clause. In 2022, the parties agreed to a two-year term without modifying the termination or late-payment provisions. About seven months into the new term, the buyer exercised its right to terminate for convenience. The seller then invoiced the buyer for the entire remaining balance of the two-year term, asserting that full payment was due despite the early termination. The buyer disputed this, arguing it owed only for services rendered up to the termination date.The case was tried without a jury in the Madison Circuit Court. The trial court found the termination-for-convenience clause ambiguous regarding payment obligations upon early termination. Relying on witness testimony and email correspondence to resolve this ambiguity, the court concluded the buyer owed the full remaining contract balance and imposed a late-payment charge, also awarding the seller its costs and attorneys’ fees.On appeal, the Supreme Court of Alabama reviewed whether the contract’s termination and late-payment provisions were ambiguous. The court held that the termination-for-convenience clause was unambiguous: the buyer was obligated to pay only for services received up to the termination date, not the full contract term. The court further found the late-payment-charge clause inapplicable because the invoice in question was disputed and not for a quarterly period as required by the contract. As a result, the Supreme Court of Alabama reversed the trial court’s judgment, including the award of attorneys’ fees and expenses, and remanded for further proceedings consistent with its opinion. View "LG Electronics Alabama, Inc. v. Velaro, Inc." on Justia Law

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