Justia Alabama Supreme Court Opinion Summaries

Yadira Ordonez, individually and as mother and next friend of her minor daughter, S.C.O., sued Capitol Farmers Market, Inc. (CFMI) in the Montgomery Circuit Court seeking damages for injuries S.C.O. sustained from hot soup purchased at Capitol International Market. CFMI moved for summary judgment, claiming it did not operate the market. Ordonez opposed the motion and requested more time for discovery. The trial court granted summary judgment in favor of CFMI, and Ordonez appealed.The trial court entered summary judgment for CFMI, finding that CFMI did not operate the grocery store or the deli where the incident occurred. Ordonez argued that more discovery was needed, particularly the deposition of CFMI's owner, John Yim, to test the veracity of his statements. The trial court denied Ordonez's motion for a continuance to conduct further discovery and granted summary judgment to CFMI.The Supreme Court of Alabama reviewed the case and found that the trial court exceeded its discretion in denying Ordonez's motion for a continuance under Rule 56(f) to take Yim's deposition. The court noted that the health department records and other evidence raised questions about CFMI's assertions that it had no employees and did not operate the grocery store or deli. The court concluded that Yim's deposition was critical to Ordonez's opposition to the summary judgment motion. Therefore, the Supreme Court of Alabama reversed the trial court's summary judgment and remanded the case for further proceedings. View "Ordonez v. Capitol Farmers Market, Inc." on Justia Law

Briana Marquise Matthews, a former prison guard, was charged with two counts of custodial sexual misconduct for having sexual encounters with an inmate. She pleaded guilty to both counts and was sentenced to 10 years, with 18 months to be served in custody and the remainder on probation. Upon starting her probation, Matthews was informed she had to comply with the Alabama Sex Offender Registration and Community Notification Act (ASORCNA) requirements.Matthews filed a petition in the St. Clair Circuit Court seeking relief from the ASORCNA requirements, arguing that these were not part of her plea agreement. The State responded that her petition was incorrectly filed in the criminal action and should be a new civil action. Matthews withdrew her petition and filed a new one as a civil action, seeking relief from the ASORCNA requirements and restrictions. The circuit court temporarily relieved her from these requirements pending further orders but ultimately denied her petition, stating that her convictions were not among those listed in § 15-20A-24(a) for which relief could be sought.The Supreme Court of Alabama reviewed the case. It dismissed the appeal from the criminal action, stating that the circuit court lacked jurisdiction to consider the petition in the criminal case, making the order void. However, the court affirmed the judgment in the civil action, agreeing that Matthews's convictions for custodial sexual misconduct were not eligible for relief under § 15-20A-24(a). The court also noted that Matthews was not entitled to seek relief while still serving her probationary term. View "Matthews v. State of Alabama" on Justia Law

In December 2021, Officer Shelton Davis of the Montgomery Police Department, while pursuing a fleeing suspect, collided with Madilyn Shuford's vehicle at an intersection in Montgomery. Officer Davis was responding to a woman's plea for help, who claimed a man was trying to kill her. The suspect, Eugene Osborne Jr., fled in a vehicle, prompting Officer Davis to pursue him with activated lights and sirens. During the pursuit, Officer Davis slowed down at a red light but collided with Shuford's vehicle when she pulled into the intersection.Shuford sued the City of Montgomery and Officer Davis, alleging negligence and wanton conduct, and claimed the City was vicariously liable. The City and Officer Davis moved for summary judgment, asserting immunity under § 6-5-338, Ala. Code 1975, and Ex parte Cranman. They provided evidence, including Officer Davis's affidavit and body camera footage, showing he was performing his duties with activated lights and sirens. Shuford opposed, arguing Officer Davis did not use proper signals and took unreasonable risks.The Montgomery Circuit Court denied the summary judgment motion without explanation. The City and Officer Davis petitioned the Supreme Court of Alabama for a writ of mandamus to vacate the denial and grant summary judgment based on immunity.The Supreme Court of Alabama granted the petition, holding that Officer Davis was entitled to immunity as he was performing his law enforcement duties and exercising judgment. The court found no substantial evidence from Shuford to refute this. Consequently, the City was also entitled to immunity. The trial court was directed to enter summary judgment in favor of the City and Officer Davis. View "Shuford v. City of Montgomery" on Justia Law

The plaintiffs filed lawsuits against two online-game companies, alleging that the companies' casino-themed social gaming applications constituted illegal gambling. The plaintiffs sought to recover money lost by Alabama residents who played these games, on behalf of the players' families, under an Alabama statute that allows such recovery. The plaintiffs did not play the games themselves and did not name any specific Alabama residents who had played the games.The defendants moved to compel arbitration based on the arbitration agreements included in the terms of service for the games, which players agreed to when they downloaded the games. The defendants also moved to dismiss the cases, arguing that the plaintiffs could not pursue mass claims on behalf of all Alabama residents who played the games and that the games were not gambling. The Franklin Circuit Court denied both the motions to compel arbitration and the motions to dismiss.The Supreme Court of Alabama reviewed the case and held that the plaintiffs, in asserting claims under the Alabama statute, were standing in the legal shoes of the players who had agreed to arbitrate their claims. Therefore, the plaintiffs' claims must be arbitrated. The court reversed the trial court's orders denying the motions to compel arbitration and remanded the cases for the trial court to grant the motions. View "Zynga, Inc. v. Mills" on Justia Law

Hembree Insurance Trust ("Hembree") leased a 135,847-square-foot industrial building in Scottsboro to Maples Industries, Inc. ("Maples") for five years starting January 1, 2020. The lease required Maples to maintain the property and share roof repair costs with Hembree. Hembree initiated a lawsuit against Maples in March 2024, alleging that Maples failed to repair or replace the roof as required by the lease.The Jackson Circuit Court treated Maples's motion to dismiss as a motion for summary judgment and ruled in favor of Maples. The court found the lease "null and void" because Hembree did not own the property, which had been transferred to Woods Cove Industrial Property, LLC ("Woods Cove") in 2014. Hembree argued that it was the sole member of Woods Cove and had the authority to lease the property, but the trial court disagreed.The Supreme Court of Alabama reviewed the case de novo. It found that Hembree, as the sole and controlling member of Woods Cove, had the authority to lease the property. The court noted that a tenant in possession generally cannot dispute the landlord's title and that Maples had accepted and benefited from the lease. The court concluded that Maples was estopped from challenging the lease based on Hembree being the named lessor. The Supreme Court of Alabama reversed the trial court's judgment and remanded the case for further proceedings. View "Hembree Insurance Trust v. Maples Industries, Inc." on Justia Law

In August 2023, the Water Works and Sewer Board of the City of Gadsden ("Gadsden Water") filed a lawsuit in the Etowah Circuit Court against several corporate defendants, including DuPont De Nemours, Inc., and Daikin America, Inc., alleging contamination of its raw-water intake from the Coosa River with perfluoroalkyl and polyfluoroalkyl substances (PFAS). Gadsden Water claimed that the defendants' actions led to substantial economic and consequential damages, including costs for future filtration systems, monitoring contamination levels, and remediation of contaminated property.Previously, in September 2016, Gadsden Water had filed a similar lawsuit ("Gadsden I") against other parties for PFAS contamination, which was settled before trial. The settlement funds were intended to cover the costs of a new water-treatment facility and its long-term operation. The Etowah Circuit Court denied motions to dismiss the current case, leading the defendants to file petitions for writs of mandamus with the Supreme Court of Alabama.The Supreme Court of Alabama reviewed the petitions. For DuPont and Daikin, the Court found that Gadsden Water's claims were barred by the applicable statutes of limitations, as the claims accrued no later than September 2016, when Gadsden Water first became aware of the PFAS contamination. The Court granted the petition for writ of mandamus, directing the Etowah Circuit Court to dismiss the claims against DuPont and Daikin.For INV Performance Surfaces, LLC, the Court determined that the Etowah Circuit Court lacked specific personal jurisdiction. INV's limited contacts with Alabama, including owning equipment in one or two Alabama carpet mills in 2006, were insufficient to establish jurisdiction. The Court granted INV's petition for writ of mandamus, directing the Etowah Circuit Court to dismiss the claims against INV. View "Ex parte DuPont De Nemours, Inc." on Justia Law

Sara Pearl Fahrmann filed a complaint against the City of Orange Beach and D.R. Horton, Inc., alleging that the City failed to ensure that Horton's construction of the Cypress Village subdivision complied with the City's zoning ordinance and the approved Planned Unit Development (PUD). Fahrmann claimed that this failure led to inadequate parking, which obstructed emergency services and delayed treatment for her husband, resulting in his death. She asserted wrongful-death claims based on wantonness and negligence.The Baldwin Circuit Court denied the City's motion for summary judgment, which argued that the City was entitled to substantive immunity from Fahrmann's claims. The City then petitioned the Supreme Court of Alabama for a writ of mandamus to direct the circuit court to grant its motion for summary judgment.The Supreme Court of Alabama reviewed the case and held that the City was immune from Fahrmann's wrongful-death claim alleging wantonness under § 11-47-190, Ala. Code 1975, which limits municipal liability to injuries caused by neglect, carelessness, or unskillfulness, and does not include wanton conduct. The Court also held that the City was entitled to substantive immunity from the negligence claim, as the City's failure to enforce its zoning ordinance did not create a legal duty to individual plaintiffs. The Court granted the City's petition and issued a writ of mandamus directing the circuit court to grant summary judgment in favor of the City. View "Ex parte City of Orange Beach" on Justia Law

In the summer of 2023, Sharonda Smith's minor child, K.S., participated in a summer program at a school operated by the Jefferson County Board of Education. On June 5, 2023, K.S. fell asleep on a bus driven by "Mr. Josh" and suffered significant emotional distress, dehydration, and other personal injuries. Smith filed a lawsuit on May 10, 2024, against the Board, "Mr. Josh," and 10 fictitiously named defendants. The Board moved to dismiss the claims against it, citing State immunity.The Jefferson Circuit Court dismissed the claims against the Board on August 1, 2024, but allowed Smith additional time to identify and serve "Mr. Josh." Smith issued subpoenas to the Board for records related to the incident, which the Board moved to quash, arguing the court lacked subject-matter jurisdiction. The court denied the motion and ordered the Board to comply with the subpoenas. Smith later identified "Mr. Josh" as Joshua Dunn and added his estate as a defendant. The Board petitioned the Supreme Court of Alabama for a writ of mandamus to vacate the discovery orders and dismiss the case for lack of jurisdiction.The Supreme Court of Alabama held that the circuit court lacked subject-matter jurisdiction because the only named defendant in the initial complaint, the Board, was entitled to State immunity, and "Mr. Josh" was a fictitiously named defendant. The court granted the Board's petition in part, directing the circuit court to vacate its discovery orders and refrain from issuing further orders against the Board. However, the court denied the Board's request to dismiss the entire action, as the Board, a nonparty, did not demonstrate a clear legal right to such relief. View "Ex parte Jefferson County Board of Education" on Justia Law

Andrew J. Scarborough, as the administrator of the estate of Timothy John Chumney, filed a lawsuit in the Montgomery Circuit Court against Wexford Health Sources, Inc., Deora Johnson, and Shari Barfield. The case involved allegations of negligence and medical malpractice following Chumney's suicide while incarcerated. The defendants initially did not object to the venue in their Rule 12 motions or answers. However, two years after the trial was first set, they moved to amend their answers to raise the defense of improper venue and filed a motion to transfer the case to Limestone Circuit Court. The Montgomery Circuit Court agreed and transferred the case.Scarborough petitioned the Supreme Court of Alabama for a writ of mandamus, arguing that the defendants had waived their defense of improper venue by not raising it earlier. The defendants contended that the transfer was mandatory under § 6-5-546 of the Alabama Medical Liability Act (AMLA), which they claimed allowed for a venue change at any time before trial.The Supreme Court of Alabama reviewed the case and determined that the defendants had indeed waived their right to challenge the venue under Rule 12(h)(1)(A) of the Alabama Rules of Civil Procedure by not including the defense in their initial motions. The court also clarified that § 6-5-546 of the AMLA did not apply because Scarborough did not allege that the acts or omissions occurred in more than one county. Therefore, the general timing provisions of Rule 12(h)(1) remained applicable.The Supreme Court of Alabama granted Scarborough's petition and issued a writ of mandamus directing the Montgomery Circuit Court to vacate its order transferring the case to Limestone Circuit Court. View "In re: Scarborough v. Wexford Health Sources" on Justia Law

Several residents of the City of Muscle Shoals filed a lawsuit against the City, seeking damages for negligence and trespass due to flooding caused by the City's management of a stormwater-drainage pond in their neighborhood. The plaintiffs claimed that heavy rainfall in February 2019 overwhelmed the pond, leading to the flooding of their homes. They argued that the City failed to plan adequately for such events and did not maintain the pond properly.The plaintiffs initially filed their complaint in the Colbert Circuit Court in March 2020, seeking damages for negligence, wantonness, and trespass. They later amended their complaint to drop the wantonness claim and added a request for injunctive relief, which the trial court denied. The City moved for summary judgment, arguing that the claims were barred by § 11-47-190, Ala. Code 1975, and that there was no substantial evidence to support the trespass claim. The trial court denied the City's motion, leading the City to file a petition for a writ of mandamus with the Supreme Court of Alabama.The Supreme Court of Alabama reviewed the case and determined that the City was immune from the plaintiffs' claims under § 11-47-190, Ala. Code 1975. The Court found that the City's decision to plan for 25-year rainfall events was within common municipal practice and did not constitute neglect, carelessness, or unskillfulness. Additionally, the Court concluded that the City's design and maintenance of the pond were not defective within the meaning of the statute. As a result, the Court granted the City's petition and issued a writ directing the trial court to enter a summary judgment in favor of the City, effectively barring the plaintiffs' claims for damages. View "In re: Burrell v. City of Muscle Shoals" on Justia Law