Justia Alabama Supreme Court Opinion Summaries

After the death of Grady L. Floyd, Sr. in Escambia County, Alabama, his family members alleged that the local medical examiner, Dr. J. Daniel Raulerson, mishandled Grady’s remains. According to the family, Dr. Raulerson failed to properly store the body, resulting in advanced decomposition, which prevented an autopsy and required cremation rather than a traditional funeral. The plaintiffs attributed this mishandling to inadequate storage and refrigeration at the county morgue, which was located at the local hospital.The plaintiffs initially sued the Escambia County Commission, individual county commissioners in both their official and personal capacities, the hospital, and later the Alabama Department of Forensic Sciences (ADFS). Their main allegations against the county defendants were based on a theory of vicarious liability for Dr. Raulerson’s actions, rather than any independent wrongdoing by the county or its commissioners. The Escambia Circuit Court denied the county defendants’ motion to dismiss the claims on immunity grounds, but granted ADFS’s motion to dismiss, finding it immune from suit.On mandamus review, the Supreme Court of Alabama considered whether the county defendants were immune from the plaintiffs’ claims. The court held that Dr. Raulerson, as medical examiner, was expressly granted immunity from civil liability for acts performed in his official capacity by § 45-27-60.11, Ala. Code 1975. Because the plaintiffs’ claims against the county defendants were entirely derivative of Dr. Raulerson’s acts, and he was immune, the county defendants could not be held vicariously liable. The Supreme Court of Alabama therefore granted the petition for writ of mandamus and directed the trial court to dismiss all claims against the county defendants. View "Ex parte Escambia County Commission" on Justia Law

A real estate investment firm based in China and another firm based in Singapore entered into a joint venture in 2021 to develop and operate a property near Auburn University. The Chinese firm held an 80% interest, while the Singaporean firm held a 20% interest and managed the venture, with full access to the joint venture’s bank accounts. The Chinese firm alleged that the manager firm made unauthorized transfers from the joint venture’s accounts, ultimately taking over $1 million. Despite partial repayment and assurances, a significant amount remained outstanding.The Chinese firm filed suit in the Lee Circuit Court, Alabama, asserting claims including declaratory judgment, fraudulent misrepresentation, conversion, and fraudulent suppression. The Singaporean firm failed to timely respond to the complaint, leading to requests for default judgment. After some delay, the manager filed an answer and engaged in discovery, but disputes arose over depositions and compliance with court orders. The trial court repeatedly addressed motions for default judgment and issues of discovery noncompliance, particularly regarding the failure of the manager’s CEO to appear for deposition. The manager later moved to compel arbitration, citing joint venture agreements containing arbitration clauses; however, the trial court ultimately entered a default judgment on liability for the Chinese firm, reserving damages, and deemed the motion to compel arbitration moot.On appeal, the Supreme Court of Alabama considered whether it had jurisdiction, given that the lower court’s judgment did not resolve damages. The Supreme Court of Alabama held that the order was interlocutory and not appealable because it did not determine damages. The court concluded that the default judgment’s interlocutory nature was not altered by the ruling on the arbitration motion, and accordingly, dismissed the appeal for lack of a final judgment. View "Ivy Fund Manager, LLC v. CDH Real Estate Investment Management Company, Ltd." on Justia Law

A property dispute arose when the estate of William King sold a property on Broad Street in Gadsden to Mobile Investments, LLC, in 2019. Corporate Pharmacy Services, Inc. (CPS), which had originally leased the property from King, claimed the lease included an option to purchase the property and that King’s estate improperly sold it without giving CPS the opportunity to exercise its right of first refusal. CPS sued Mobile Investments and The Broadway Group, LLC (TBG), alleging breach of the lease and seeking specific performance of the purchase option. After Mobile Investments and TBG repeatedly failed to comply with discovery requests and court orders, the Etowah Circuit Court entered a default judgment against them, ordering that CPS was entitled to purchase the property for $110,000.Mobile Investments and TBG first moved for relief from the default judgment, which was denied. They appealed to the Supreme Court of Alabama, arguing they had not been properly informed by their counsel about discovery orders and their consequences. The Supreme Court of Alabama affirmed the trial court’s judgment. Afterward, Mobile Investments and TBG filed a Rule 60(b)(4) motion, later amended to add Rule 60(b)(6) grounds, seeking to set aside the judgment as void for lack of due process and to correct the property description. The trial court denied the motion in large part but scheduled a further hearing to resolve issues regarding the legal description of the property and the corresponding purchase price.Before the trial court could complete its proceedings on these unresolved issues, Mobile Investments and TBG appealed again to the Supreme Court of Alabama. The Supreme Court of Alabama held that because the trial court had not yet issued a final judgment—leaving substantive issues pending—it lacked jurisdiction over the appeal. Accordingly, the appeal was dismissed. View "Mobile Investments, LLC v. Corporate Pharmacy Services, Inc." on Justia Law

A couple alleged that their home in Union Springs suffered significant roof damage from a storm in January 2024. They had a homeowners’ insurance policy with an insurer and submitted a repair estimate of $9,112.02 to the company, which responded with a significantly lower settlement offer. The couple sued the insurer in the Bullock Circuit Court, claiming breach of contract and bad faith, and alleged a systematic practice by the insurer of underpaying roof claims. During discovery, the couple requested documents relating to the handling of roof claims. The insurer objected, citing concerns over the breadth of the requests and the confidential nature of certain documents.After both sides submitted competing motions for protective orders, the circuit court entered an order that allowed some confidential materials produced by the insurer to be used not only in the couple’s case but also in other cases handled by their counsel involving similar claims against the insurer. The order also permitted sharing information with governmental agencies under certain conditions. The insurer petitioned the Supreme Court of Alabama for a writ of mandamus, seeking to vacate the protective order and require a more restrictive, non-sharing version.The Supreme Court of Alabama held that there is no per se prohibition against sharing provisions in protective orders, provided there are adequate safeguards. The court concluded that the circuit court did not exceed its discretion in allowing sharing with government entities. However, it required the protective order to be modified to (1) specify the exact cases in which sharing is permitted, (2) require all recipients to agree in writing to be bound by the order and submit to the circuit court’s jurisdiction, and (3) clarify obligations for returning or destroying confidential materials at the conclusion of each case. The petition for mandamus was granted in part and denied in part, and the writ was issued accordingly. View "Ex parte State Farm Fire and Casualty Company" on Justia Law

A group of individuals who worked for Greene County sued the Greene County Commission, alleging negligence, outrage, trespass, and nuisance due to injuries from rodent infestations and faulty building systems in the county courthouse. The Greene County Commission was a member of a self-insurance fund operated by the Association of County Commissions of Alabama Liability Self-Insurance Fund, Inc. The association provided a defense to the county commission in the tort action under a reservation of rights. In June 2024, the association initiated a declaratory-judgment action against the county commission and the county workers, seeking a determination that certain claims were excluded from coverage under the insurance agreement and asserting it had no duty to defend the county commission in the tort action.The Greene Circuit Court heard motions to dismiss the declaratory-judgment action, with the county workers arguing it was not ripe until the tort action was resolved and the county commission contending the association was obligated to defend. On December 1, 2025, the circuit court stayed the declaratory-judgment action pending the outcome of the tort action, reasoning that resolving coverage issues could supersede issues already pending in the tort action.The Supreme Court of Alabama reviewed the association’s petition for a writ of mandamus to vacate the circuit court’s stay. The Supreme Court held that the circuit court exceeded its discretion by staying the declaratory-judgment action as it related to the association’s request for a determination of its duty to defend. The court granted the petition and issued a writ directing the circuit court to proceed with the declaratory-judgment action on the duty-to-defend issue, but not on indemnification issues. The disposition was to vacate the stay as to the duty to defend. View "Ex parte Association of County Commissions of Alabama Liability Self-Insurance Fund, Inc." on Justia Law

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