Justia Alabama Supreme Court Opinion Summaries

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

The case concerns a defendant who was convicted in Mobile Circuit Court of both pharmacy robbery and first-degree robbery. Because he had four prior felony convictions, the State invoked Alabama’s Habitual Felony Offender Act (HFOA) during sentencing. For the pharmacy-robbery conviction, the trial court sentenced him to life imprisonment without the possibility of parole, believing this sentence was mandatory due to the interplay between the HFOA and the Pharmacy Robbery Act, which generally makes those convicted of pharmacy robbery ineligible for parole. For the first-degree robbery conviction, he received a 240-month prison sentence.The defendant appealed to the Alabama Court of Criminal Appeals. That court affirmed the pharmacy-robbery conviction and the accompanying sentence, while reversing the first-degree robbery conviction and remanding with instructions to vacate it. On return to remand, the Court of Criminal Appeals affirmed the judgment in its entirety. The defendant then sought review from the Supreme Court of Alabama, challenging the portion of the Court of Criminal Appeals’ decision affirming his sentence for pharmacy robbery.The Supreme Court of Alabama held that, under the plain language of the HFOA, when that law is properly invoked, the trial court has discretion to sentence a qualifying offender either to life imprisonment with the possibility of parole or to life imprisonment without the possibility of parole. The Supreme Court found that the trial court erred by concluding it was required to impose a sentence without parole, and that the lower appellate court erred in upholding this approach. Accordingly, the Supreme Court reversed the judgment of the Court of Criminal Appeals as to the pharmacy-robbery sentence and remanded the case for further proceedings consistent with its opinion. View "Ex parte Spencer" on Justia Law

The case involves a nonprofit religious organization in Shelby County that hosted a wedding reception for two of its missionaries. The organization hired a catering company for the event, and the plaintiff, who operated a catering business, was brought in by another caterer associated with the company to help with the reception. She was paid for her work and arranged for additional staff to assist. At the end of the event, the plaintiff was directed by a member of the organization to exit the building through a specific door. It was dark outside, and there was no exterior lighting in the area. After stepping outside, the plaintiff took a few steps and fell off a loading dock, sustaining serious injuries.The plaintiff sued the organization in the Shelby Circuit Court, alleging negligence, wantonness, and negligent or wanton hiring, training, and supervision. The organization moved for summary judgment, arguing that the plaintiff was a licensee rather than a business invitee and that any danger was open and obvious due to the darkness. The trial court granted summary judgment in favor of the organization. The plaintiff appealed, contesting only the negligence claim.The Supreme Court of Alabama reviewed the case de novo. It determined that the plaintiff was a business invitee because she was present to provide a material benefit to the organization. The court further held that whether the darkness constituted an open and obvious danger was a question of fact for the jury, not an issue to be resolved on summary judgment, because there was evidence the lighting was not total darkness and could have misled a reasonably prudent person. The Supreme Court of Alabama reversed the summary judgment on the negligence claim and remanded the case for further proceedings. View "Joseph v. Caritas of Birmingham" on Justia Law

The Town of Pine Hill sued several corporations and individuals in the Wilcox Circuit Court, claiming that chemical contamination from upstream industrial facilities, including per- and poly-fluoroalkyl substances (PFAS), polluted the Town’s drinking water supply from the Alabama River. The Town alleged that these chemicals, released via wastewater, air, and stormwater emissions, exceeded federal health guidelines, could not be removed by current treatment processes, and caused harm. The Town sought damages for remediation, future filtration costs, and injunctive relief. The complaint stated that no federal cause of action was asserted and noted that most defendants were out-of-state corporations.After the suit was filed, 3M Company, Inc. removed the case to the United States District Court for the Southern District of Alabama, citing federal-officer removal under 28 U.S.C. § 1442 and diversity jurisdiction. The district court remanded the case to state court, but 3M appealed the remand order to the United States Court of Appeals for the Eleventh Circuit. The district court stayed its remand order pending appeal, even after transmitting it to the state court. The Town argued that jurisdiction returned to the circuit court upon remand, and the Wilcox Circuit Court agreed, ordering litigation to proceed.The Supreme Court of Alabama held that because the removal was under 28 U.S.C. § 1442, the remand order was appealable and the federal district court retained jurisdiction to stay or reconsider its remand order, even after transmitting it to the state court. The circuit court acted without jurisdiction by proceeding while the remand order was stayed. Therefore, the Supreme Court of Alabama issued a writ of prohibition, requiring the circuit court to vacate its order asserting jurisdiction and to stay proceedings until the federal appeal is resolved. View "Town of Pine Hill v. 3M Company, Inc." on Justia Law

Barbara Tanzer, an elderly woman, and her husband moved through several states, ultimately leasing an apartment in Alabama to allow her husband to receive medical treatment. Shortly after their arrival, the Alabama Department of Human Resources (DHR) petitioned for protective services, alleging Barbara was unable to care for herself and at risk of exploitation. DHR cited Barbara’s physical and cognitive limitations and alleged suspicious financial activity by a third party using a power of attorney. Barbara was evaluated twice by medical professionals, who found she did not suffer from significant cognitive impairment and retained capacity for medical decision-making, though she required physical assistance. Barbara asserted that her presence in Alabama was temporary and that she remained domiciled elsewhere.After DHR’s petition, the Jefferson Probate Court issued emergency protective orders, froze Barbara’s assets, and ultimately appointed a permanent conservator for her estate. Throughout the proceedings, Barbara maintained that the court lacked personal jurisdiction, as she did not reside in Alabama, had no family or assets there, and was only temporarily present for her husband’s medical care. She sold her Georgia property, purchased a condominium in Massachusetts, and notified the probate court of her permanent move out of Alabama.The Supreme Court of Alabama reviewed the case and determined that the probate court lacked personal jurisdiction under the Alabama Uniform Adult Guardianship and Protective Proceedings Act. The Court found that Alabama was neither Barbara’s home state nor a significant-connection state at the time the petition was filed, and none of the statutory bases for jurisdiction applied. Consequently, the Supreme Court of Alabama reversed the probate court’s order appointing a conservator and remanded the case for further proceedings. View "Tanzer v. Alabama Department of Human Resources" on Justia Law

Three individuals, Barbara Moore, Vanessa Reed, and Christine Burrell, served as members of the Lipscomb City Council, each representing a different district. After a city council meeting in May 2025, the council rejected a proposed redistricting plan and resolved to keep district boundaries unchanged. However, in the August 2025 municipal election, the election was conducted using the rejected redistricting map. Despite this, the three council members were sworn into office for their respective districts under the original boundaries. Mayor Robin Sims, claiming the council members no longer met residency requirements due to the district lines used in the election, filed for a temporary restraining order (TRO), a permanent injunction, and a writ of quo warranto, seeking their removal from office.The Jefferson Circuit Court, Bessemer Division, issued the TRO, then granted the writ of quo warranto and the permanent injunction, finding that the council members did not meet the statutory residency requirements and declaring their seats vacant. The court denied the council members’ motion to dismiss and their subsequent postjudgment motion, holding that they were unlawfully occupying their seats. The court also denied their request to stay enforcement of its judgment pending appeal.On appeal, the Supreme Court of Alabama reviewed whether the trial court had subject-matter jurisdiction. The Supreme Court held that the trial court lacked subject-matter jurisdiction because the statutory requirement that an informant provide security for costs at the commencement of a quo warranto action was not satisfied. The bond posted was solely for the injunction, not for the quo warranto proceeding. Because this requirement is jurisdictional, the trial court’s judgment was void. The Supreme Court of Alabama reversed the judgment and remanded the case with instructions for the trial court to vacate its judgment. View "Moore v. State of Alabama ex rel. Mayor Sims" on Justia Law

Two grandchildren of Edward and Betty Stewart brought suit against their uncle following the administration of two family trusts. The trusts, governed by Illinois law, were originally structured to provide for Edward and Betty’s children, including the grandchildren’s mother. After their mother’s death in 2017, Betty amended the trusts to designate her son Bruce as sole beneficiary. The grandchildren made repeated requests for information about the trusts, which were denied on the grounds that they were not beneficiaries. After Betty’s death in 2023, and confirmation that they had been excluded, the grandchildren sued Bruce, alleging undue influence, lack of capacity, breach of trust, and tortious interference with inheritance.The case was first heard by the Mobile Circuit Court. Bruce moved for summary judgment, asserting that the claims were time-barred and that certain claims were not recognized under Alabama law. The plaintiffs responded that Illinois law governed and that the statute of limitations should be tolled due to Bruce’s concealment of their removal as beneficiaries. After considering arguments from both parties, the circuit court granted summary judgment for Bruce, finding all claims time-barred, prompting the appeal.Upon review, the Supreme Court of Alabama found that the plaintiffs’ attorney had filed appellate briefs rife with invalid, inaccurate, and non-existent legal citations, many generated by artificial intelligence. The Court determined these briefs were grossly deficient and failed to comply with the Alabama Rules of Appellate Procedure. As a result, the Supreme Court of Alabama dismissed the appeal, denied the plaintiffs’ motion to file supplemental briefs, imposed sanctions on plaintiffs’ counsel, and granted counsel’s motion to withdraw. The main holding is that an appeal supported by fabricated or grossly deficient legal authorities does not meet minimum procedural standards and will be dismissed. View "Ibach v. Stewart" on Justia Law