Justia Alabama Supreme Court Opinion Summaries

A motorcyclist suffered severe injuries after crashing on Avenue V in Birmingham due to a defect in the road. He submitted a notice of claim to the City of Birmingham within six months as required by state law and later filed a negligence lawsuit, alleging the City failed to repair the defect after being notified. The key factual dispute involved whether the City had actual or constructive knowledge of the defect prior to the accident.The Jefferson Circuit Court reviewed the case and, after discovery, denied the City’s initial motion for summary judgment. The City later renewed its motion, attaching new evidence and seeking to strike some of the plaintiff’s evidence. The trial court struck several items, including an affidavit, an unsworn witness statement, and a patient-care report, but again denied summary judgment. The City’s motion for reconsideration was denied, prompting it to petition for a writ of mandamus.The Supreme Court of Alabama reviewed the petition, focusing on whether the City was entitled to municipal immunity. Applying a de novo standard, the court found that the admissible evidence did not create a genuine issue of material fact as to whether the City had actual or constructive knowledge of the defect. The court held that the plaintiff’s remaining evidence was speculative and insufficient to overcome the City’s prima facie case for immunity. The court granted the City’s petition, issued the writ of mandamus, and directed the trial court to vacate its order denying summary judgment and instead grant summary judgment in favor of the City. View "In re: Stoudmire v. City of Birmingham" on Justia Law

A group of individuals who had received traffic citations under a local ordinance enacted by the City of Tuskegee permitting automated photographic enforcement of traffic laws brought suit against the City, certain city officials, and JENOPTIK, the company involved in the installation and operation of the enforcement devices. The plaintiffs challenged the validity of the ordinance, raised constitutional concerns, and sought declaratory and injunctive relief as well as damages, including tort claims for negligence, invasion of privacy, and fraud. The City later enacted resolutions cancelling outstanding citations, refunding fines, and ultimately suspending enforcement of the ordinance.The case was initially filed in the Macon Circuit Court. The City and JENOPTIK moved to dismiss, arguing lack of a justiciable controversy, mootness, lack of standing, and other grounds, including lack of personal jurisdiction over JENOPTIK. The trial court denied these motions to dismiss, treating them as motions under Rule 12 and excluding extraneous materials, but did not provide detailed reasoning.On review, the Supreme Court of Alabama held that because the plaintiffs either paid the fines or failed to contest the citations under the administrative procedures provided in the ordinance, and because the City subsequently nullified the citations and provided for reimbursement, their claims challenging the legality of the ordinance were moot. The Court directed the trial court to dismiss those claims. However, the Supreme Court denied the petitions insofar as they sought dismissal of the plaintiffs’ tort claims, holding that the City and JENOPTIK did not demonstrate a clear right to mandamus relief on those claims at this stage. The Court likewise declined to dismiss the tort claims against JENOPTIK for lack of personal jurisdiction based on the current record. View "In re: Busby v. City of Tuskegee" on Justia Law

The plaintiffs, a trade association and a vape shop operator, filed suit challenging an Alabama law regulating electronic nicotine delivery systems (ENDS), which includes e-cigarettes and vapes. The law, effective June 1, 2025, established strict requirements for the sale of ENDS, including a product directory listing only approved products, mandates that products be manufactured in the United States or have federal FDA marketing authorization, and imposed significant penalties for violations. The plaintiffs claimed these regulations would cause them immediate and irreparable harm, including loss of profits, employees, and potential closure of their businesses due to prohibitions and penalties outlined in the law.The Montgomery Circuit Court initially granted a temporary restraining order (TRO) in favor of the plaintiffs, finding they would suffer irreparable harm and had no adequate remedy at law because the State defendants were protected by sovereign immunity. After a hearing, the court denied the plaintiffs’ motion for a preliminary injunction but extended the TRO pending appeal. The State defendants appealed, challenging the plaintiffs’ standing, while the plaintiffs cross-appealed the denial of the preliminary injunction.The Supreme Court of Alabama reviewed both appeals. It held that the plaintiffs had standing, as they faced concrete, particularized, and actual harm directly resulting from the enforcement of the Alabama law. However, the Court found the plaintiffs did not demonstrate a reasonable likelihood of success on the merits of their constitutional claims, including implied preemption and dormant Commerce Clause challenges. The Court determined that the Alabama Act was not preempted by federal law and served legitimate state interests related to health and safety. Therefore, the Supreme Court of Alabama affirmed the trial court's denial of the preliminary injunction. View "Spencer v. Vapor Technology Association" on Justia Law

After suffering personal injuries in a motor-vehicle accident, a plaintiff obtained a default judgment in 2005 against the defendant for $1,500,000. More than a decade later, the plaintiff revived the judgment and secured a writ of garnishment against the defendant’s wages through her employer, a property management company. Wage garnishment payments were made for nearly eight years. In 2024, the employer sold most of its assets to another company, and the defendant’s employment with the original employer ended.Following this, the employer (now renamed) moved to be released from its garnishment obligations, arguing that, since the defendant was no longer employed, it held no further wages subject to garnishment. The motion was signed by the employer’s attorney but did not include a separate affidavit as typically required by statute. The Madison Circuit Court granted the motion the next day, releasing the employer from the garnishment. On that same day, the plaintiff requested the court to set aside the release, citing the lack of affidavit and seeking the right to orally examine the employer under state law. The plaintiff also moved to substitute the successor employer as garnishee. The trial court did not rule on these motions within the required period, so they were deemed denied by operation of law.The Supreme Court of Alabama reviewed the case. The court held that the employer’s amended answer, though lacking a formal affidavit, substantially complied with statutory requirements due to the attorney’s certification. However, the trial court erred by not granting the plaintiff’s timely request to orally examine the employer under the applicable statute. The Supreme Court reversed the trial court’s judgment and instructed it to permit the oral examination as required by law. View "Moore v. Capesius" on Justia Law

A Mississippi construction company, operating under the name MCA Construction, Inc., entered into a contract with an Alabama property owner to perform site development work on a residential subdivision in Baldwin County. The contract was executed on February 11, 2021, and at that time, the company held an Alabama general contractor’s license with a “Building Construction” (BC) classification and an unlimited bid limit. Shortly before executing the contract, the city engineer raised questions regarding whether the BC classification was adequate for the planned utility work (such as water and sewer installation) and indicated that an additional “Municipal and Utility” (MU) classification might be required before such work began. MCA sought clarification from the state licensing board and subsequently obtained the MU classification in May 2021, before starting the utility work.The property owner, RAM-Robertsdale Subdivision Partners, LLC, along with related parties, later alleged that MCA had performed defective work and failed to pay subcontractors, and they brought suit in Baldwin Circuit Court. MCA filed counterclaims for breach of contract and fraud, asserting that it had not been fully paid for its work. The RAM parties moved for summary judgment, arguing that the contract was void because MCA was not properly licensed with the MU classification at the time the contract was executed.The Baldwin Circuit Court granted summary judgment for the RAM parties, holding that the contract was void because MCA was not “duly licensed” for all aspects of the work at the time of contracting. MCA appealed. The Supreme Court of Alabama reviewed the statutory and regulatory framework, noting that MCA had a valid BC license, acted in good faith, and obtained the MU classification before performing utility work. The Supreme Court of Alabama held that substantial compliance with the licensing statute was sufficient in these circumstances and that voiding the contract was not warranted. The court reversed the summary judgment and remanded for further proceedings. View "Construction Services, LLC v. RAM-Robertsdale Subdivision Partners, LLC" on Justia Law

A woman was seriously injured as a passenger in a car accident in Montgomery County, Alabama. She first received treatment at one hospital and was then transferred to another for further care. Both hospitals, which are affiliated with public entities, filed statutory hospital liens in probate courts to secure payment for her medical expenses from any settlement or recovery she might obtain related to her injuries. The total amount of the liens exceeded the amount available from the car owner’s insurance, which provided $75,000 in coverage. The woman settled with the insurance company and received a portion of the proceeds, with the rest held by her attorney pending resolution of the hospital liens.Afterward, she filed an action in the Montgomery Circuit Court, seeking interpleader and declaratory relief to determine the validity and amounts of the hospitals’ liens. One hospital, the University of South Alabama Health University Hospital, argued it was immune from suit under Article I, § 14, of the Alabama Constitution because it is a state agency. The trial court agreed, found that the state hospital was a necessary party, and dismissed the claims against both hospitals with prejudice, concluding it lacked subject-matter jurisdiction.The Supreme Court of Alabama reviewed the dismissal de novo. It held that an interpleader action brought under Rule 22 of the Alabama Rules of Civil Procedure to resolve the validity and amount of hospital liens does not implicate state immunity and does not deprive the trial court of jurisdiction, even when a state entity is named as a defendant. The Court reversed the trial court’s dismissal and remanded the case for further proceedings, allowing the plaintiff’s interpleader claim to go forward. View "Wood v. Health Care Authority for Baptist Health" on Justia Law

A house in Hoover, Alabama was owned by William and Roberta as joint tenants with rights of survivorship. After William’s death in 2012, Roberta remained at the property, later joined by her son, Parker, who eventually married Hall. Roberta died in 2019, and Parker claimed he became the property owner as her sole heir. The mortgage, originally executed with Countrywide Home Loans and later assigned to The Bank of New York Mellon (BONY), went into default, leading to foreclosure in 2021. BONY purchased the property at foreclosure, but Parker and Hall did not vacate. BONY filed an ejectment action in 2022, initially naming William and Roberta (both deceased) as defendants, later substituting Parker, Hall, and the estate of Roberta.The Shelby Circuit Court granted summary judgment for BONY and Select Portfolio Servicing (SPS), ordering Parker and Hall to make payments into court, granting BONY immediate possession, declaring Parker and Hall forfeited any right of redemption for failing to vacate, and granting judgment against their counterclaims.The Supreme Court of Alabama reviewed the case and first addressed whether the circuit court had subject-matter jurisdiction. The Supreme Court held that, because the original complaint only named deceased persons as defendants, the action was void from its inception and did not invoke the jurisdiction of the trial court. Consequently, the circuit court had no authority to entertain amendments, substitute the estate, or address any further motions or pleadings. The Supreme Court of Alabama reversed the lower court’s order and remanded with instructions for the trial court to vacate its order and dismiss the action, without prejudice. This disposition was based solely on the jurisdictional defect, pretermitting other arguments. View "Parker v. The Bank of New York Mellon" on Justia Law

An individual sought appointment to a municipal position as Park and Recreation Director in a city, claiming the support of a majority of the city's separately incorporated Public Park and Recreation Board. Despite this support, the mayor appointed a different candidate. The individual then filed suit against the city, the mayor, the city administrator, and the Board, asserting that the city officials had improperly prevented the Board from exercising authority to select the Park and Recreation Director. The plaintiff based his claims on statutes granting certain employment powers to public park boards and on the Board’s bylaws, which he argued gave the Board authority over the director’s appointment.In the Jefferson Circuit Court, the defendants moved to dismiss the complaint. The circuit court granted the motions, finding that the plaintiff failed to state a claim against the City, that the mayor and administrator had state-agent immunity, and that there was no alleged wrongdoing by the Board. After the plaintiff unsuccessfully sought to alter or amend the judgment, he appealed.The Supreme Court of Alabama reviewed the case under the standard that requires viewing the complaint’s allegations in the plaintiff’s favor to determine if any set of facts could entitle him to relief. The Court held that the plaintiff lacked standing to sue the Board because he did not allege any actionable injury caused by the Board; the injury he suffered—failure to be hired—was attributable to city officials, not the Board. As for the city defendants, the Court found the plaintiff failed to state any valid legal claim, as the authority to appoint the city’s Park and Recreation Director resides with the mayor by statute, not the Board. Accordingly, the Supreme Court of Alabama affirmed the circuit court’s dismissal of the complaint. View "Wilder v. The City of Hoover" on Justia Law

Two brothers became parties to a dispute over the inheritance of their father’s estate after the father died intestate. One brother, Christopher, asserted that his sibling, Daniel, was not the biological child of their father, Ernest, and therefore not entitled to inherit. Christopher petitioned for letters of administration in the probate court, claiming to be Ernest's sole heir. The probate court granted him letters of administration. Christopher then sought to remove the estate administration to the circuit court, filing a petition that was not verified under oath as required by Alabama law. The circuit court entered an order removing the administration and later, based on DNA evidence, an affidavit from the mother, and Daniel’s marriage certificate, declared that Daniel was not Ernest’s biological child or heir.After the circuit court’s order, Daniel filed a postjudgment motion arguing that the removal of the estate administration was invalid because Christopher’s initial removal petition was not sworn, as required by Ala. Code § 12-11-41. Around the same time as the hearing on this motion, Christopher submitted an amended, sworn petition for removal, and the circuit court then entered a new order granting removal. However, this action occurred after the circuit court had already issued its prior order resolving the inheritance dispute.The Supreme Court of Alabama held that the circuit court’s jurisdiction over the estate administration was not properly invoked until a sworn petition was filed, as mandated by statute. Thus, the July 2025 order declaring Daniel not an heir was void due to lack of subject-matter jurisdiction at the time it was entered. The Supreme Court of Alabama reversed the circuit court’s order and remanded the case with instructions to vacate the July 2025 order. View "Thomas v. Thomas" on Justia Law

A real estate transaction in Shelby County, Alabama, gave rise to this dispute. In 2007, a property owner named Ellison financed the purchase of her home with a loan secured by a mortgage, which was eventually sold to U.S. Bank Trust National Association and serviced by SN Servicing Corporation. After Ellison defaulted, U.S. Bank bought property at a foreclosure sale. Due to confusion over addresses and a lack of a survey, U.S. Bank and its agent mistakenly believed they were selling the Ellison property, a valuable bricked double-wide trailer, to Marco J. Bonilla. Bonilla purchased the property for $95,000, but later discovered that the deed conveyed a different and less valuable property. He was unable to resell the property he believed he owned.Bonilla sued U.S. Bank and SN Servicing in the Shelby Circuit Court, asserting claims for conversion, breach of contract, negligence, wantonness, and sought rescission of the deed. Both sides moved for summary judgment. The circuit court granted summary judgment for Bonilla on all claims, rescinded the transaction, ordered Bonilla to execute a quitclaim deed returning the property, and awarded him $114,000 in compensatory damages, $14,913.70 in interest, and $75,000 in punitive damages for wantonness. The court denied the defendants’ postjudgment motion without a hearing.On appeal, the Supreme Court of Alabama affirmed summary judgment for Bonilla on his claims for conversion, breach of contract, and negligence, as well as the compensatory and interest awards. However, the Court reversed the summary judgment on the wantonness claim and the award of punitive damages, holding that wantonness involves disputed factual issues concerning the defendants’ mental state that should be determined by a jury. The case was remanded for further proceedings on wantonness and punitive damages. View "U.S. Bank Trust National Association v. Bonilla" on Justia Law