Justia Alabama Supreme Court Opinion Summaries

The Alabama Educational Television Commission petitioned the Supreme Court for a writ of mandamus to direct the Jefferson Circuit Court to dismiss claims brought against them by Allan Pizzato and Pauline Howland and to strike Pizzato and Howland's second amended complaint. From 2000 until June 2012, Pizzato served as the executive director of Alabama Public Television ("APT") and Howland served as the deputy director and chief financial officer of APT. Sometime before June 2012, tension arose between Pizzato and the Commissioners. At its regular quarterly meeting in June 2012, the Commission voted to go into executive session to discuss Pizzato's "general reputation, character, and job performance." After the Commission returned to its regular meeting from the executive session, the Commissioners moved to terminate Pizzato's and Howland's employment, stating that "the Commission had decided to move APT in a new direction." Thereafter, Pizzato requested certain materials from the Commission pursuant to the Open Records Act. A month later, Pizzato sued the Commission and the Commissioners in their individual and official capacities, alleging violations of the Open Meetings Act, seeking compensatory and punitive damages. The Commissioners moved the circuit court to dismiss Pizzato's claims against them, arguing that Pizzato did not have standing to bring an Open Meetings Act claim, that the Open Meetings Act did not provide for the recovery of compensatory or punitive damages, and that the complaint failed to state a claim under the Open Meetings Act. Further, the Commissioners argued that Pizzato's claim was moot because the requested documents had been produced and that the circuit court did not have subject-matter jurisdiction over the request for a declaratory judgment because the allegations supporting that count failed to state a claim upon which relief could be granted. After a hearing, the circuit court denied the Commission and the Commissioners' motions, including the motion for a permissive appeal under Rule 5, Ala. R. App. P. The Commission and the Commissioners then petitioned the Supreme Court for mandamus relief. After review of the circuit court record, the Supreme Court concluded the court erred in its decisions denying the Commissioners' motions. Because Pizzato and Howland had not established standing to bring their action against the Commission and the Commissioners under the Open Meetings Act, the claims asserted in both the first amended and second amended complaints should have been dismissed. Therefore, the Court granted the petition for mandamus relief and issued the writ. View "Pizzato v. Alabama Educational Television Commission" on Justia Law

Defendants Alabama Psychiatric Services, P.C. ("APS"), and Managed Health Care Administration, Inc. ("MHCA"), appealed the trial court's order denying their motions for a judgment as a matter of law. Although the jury entered a verdict for APS and MHCA, they nonetheless argued that two claims that were ultimately tried should not have been submitted to the jury. APS and MHCA also appealed the trial court's order granting a motion for a new trial filed by plaintiff A Center for Eating Disorders, L.L.C. ("ACED"). ACED opened its doors under the name Alabama Center for Eating Disorders and using the acronym ACED. Shortly thereafter, APS filed a trademark infringement lawsuit against ACED, arguing that ACED's name infringed on the name of APS's eating-disorder center. ACED voluntarily changed its name to A Center for Eating Disorders so that it could continue to use the acronym ACED, and the trademark-infringement lawsuit was dismissed. After MHCA refused to allow ACED to apply as a services provider for the network of mental-health professionals treating patients insured by Blue Cross Blue Shield of Alabama ("Blue Cross"), ACED filed its own seven-count lawsuit against APS, MHCA, and Blue Cross. The Supreme Court reversed the trial court's order denying APS's and MHCA's motions for a judgment as a matter of law as to ACED's intentional interference-with-business-relations and conspiracy claims, and the Court reversed the order granting ACED's motion for a new trial. View "Alabama Psychiatric Services, P.C. v. A Center for Eating Disorders, L.L.C. " on Justia Law

Dr. Ann M. Mottershaw and The Radiology Group, LLC, appealed the trial court's order granting a motion for a new trial filed by plaintiff Shannon Ledbetter, as administrator of the estate of Venoria Womack. These appeals primarily concerned whether the trial court exceeded its discretion in ordering a new trial based on the jury's exposure to certain evidence that the trial court had excluded by an order granting a motion in limine. Upon review of the trial court record, the Supreme Court concluded that the trial court did not exceed its discretion, and affirmed its decision. View "Mottershaw v. Ledbetter" on Justia Law

The Supreme Court granted certiorari to review the Court of Criminal Appeals' decision that it did not have jurisdiction to entertain Earnest Walker's appeal from the new sentence imposed for his 2006 guilty-plea conviction for second-degree receiving stolen property. The new sentence was imposed after it was determined, following Walker's filing a Rule 32, Ala. R. Crim. P., petition, that Walker's original sentence exceeded the maximum authorized by law. The Court of Criminal Appeals dismissed Walker's appeal. The Supreme Court reversed and remanded, finding the trial court's exercise of discretion created a significant difference between the facts in the controlling case law and those in this case. "[D]ue process mandates that Walker have an opportunity to appeal his new sentence." View "Walker v. Alabama " on Justia Law

In 2008, James Ware was convicted of first-degree rape, first-degree burglary, and first-degree robbery, for which he was sentenced as an habitual felony offender to three sentences of life imprisonment, to be served consecutively. Ware appealed his convictions to the Court of Criminal Appeals. The Court of Criminal Appeals affirmed. On appeal to the Court of Criminal Appeals, Ware argued: (1) the trial court violated his Sixth Amendment right to confront the witnesses against him when it admitted a DNA-profile report that was based on the work of laboratory technicians who did not testify at trial; and (2) the trial court erred in denying his motion for a judgment of acquittal on the robbery and burglary charges because there was not sufficient evidence to prove beyond a reasonable doubt that he was armed with a deadly weapon or a dangerous instrument. The Supreme Court affirmed as to the first issue and reversed as to the second. View "Ware v. Alabama " on Justia Law

In order to meet the 300 inhabitants required for incorporation under section 11-41-1, the petitioners included 51 people actually living in Caritas Village along with 296 people who had declared that they have designated Caritas Village as their place of residence pursuant to 12-13-23, Ala. Code 1975. The probate court determined that: (1) the proposed municipality had a population of less than 300; (2) the population of the proposed municipality did not constitute a body of citizens whose residences were contiguous and formed a homogeneous community; (3) the application was not signed by at least 15 percent of the qualified electors residing within the municipality limits; (4) there were not 4 qualified electors residing on each quarter of a quarter section of the platted or unplatted lands; (5) the application did not contain an accurate plat of the land to be included within the proposed corporate limits; (6) the place of residence by street and number of those living within the proposed municipality was not included; and (7) the petition did not accurately state the name of the proposed municipality. The issue before the Supreme Court was whether the probate court erred in its determination, and whether the declarations of residency were indeed sufficient under 11-41-1. After careful consideration of the probate court record, the Supreme Court concluded petitioners' declarations were not sufficient to meet the statute's requirements, and therefore affirmed the probate court's decision. View "In re The incorporation of Caritas Village" on Justia Law

This case involves a dispute between Bessemer Water Service (BWS) and Lake Cyrus Development Company, Inc. (LCDC) over a contract referred to as the "1998 water agreement." In "Bessemer I," the Supreme Court concluded that the trial court had exceeded its discretion in holding that the 1998 water agreement was a valid binding contract and in awarding LCDC $224,979.83 because the agreement was entered into violation of section 39-2-2 and was therefore void. On appeal, the Attorney General intervened and filed a complain seeking to recover payments BWS made to LCDC under the 1988 water agreement. The trial court ultimately entered a judgment in favor of the Attorney General (for the benefit of BWS). LCDC thereafter filed a postjudgment motion requesting the trial court alter, amend or vacate its judgment, or in the alternative, order a new trial. The trial court denied LCDC's motion; that denial was brought before the Supreme Court in this case. After review, the Supreme Court held the trial court's denial of LCDC's motion should have been reversed. The case was then remanded for further proceedings. View "Lake Cyrus Development Company, Inc. v. Bessemer Water Service " on Justia Law

Pennsylvania National Mutual Casualty Insurance Company filed suit against Roger D. Allen, Homeland Vinyl Products, Inc., and Deric Miner, individually and as the personal representative of the estate of Jane Miner, seeking a declaratory judgment that it owed no duty of defense or indemnity to Allen for claims arising out of a fatal automobile accident that occurred in New Jersey. Allen was a New Jersey resident, and moved to dismiss the claims against him for lack of personal jurisdiction. In response, the trial court dismissed the case in its entirety. The insurance company appealed that decision. But finding no reversible error, the Supreme Court affirmed. View "Pennsylvania National Mutual Casualty Insurance Company v. Allen " on Justia Law

Edward Crabtree slipped and fell on the top floor of physician's parking deck of a medical center owned by Mobile Infirmary Associates d/b/a Mobile Infirmary Medical Center, and he suffered injuries as a result. The Crabtrees sued, naming as defendants in the lawsuit Mobile Infirmary and fictitiously named parties; BASF was one of the parties the Crabtrees substituted for a fictitiously named defendant in an amended complaint. The Crabtrees contended BASF was liable for Edward Crabtree's fall because a polyurethane product called Sonoguard, which was manufactured by BASF's predecessor ChemRex, Inc. was improperly installed on the floor of the parking deck where Edward Crabtree fell and sustained his injuries. BASF petitioned for a writ of certiorari, questioning the ruling of the Court of Civil Appeals with respect to the statute of limitations and with respect to the issues of duty and whether there was substantial evidence to support the Crabtrees' claims. The facts and circumstances of this case lead the Supreme Court to conclude that BASF did not assume a duty to provide more advice or assistance to CHP than it actually provided. Further, the record did not contain substantial evidence that BASF failed to exercise due care in providing the particular advice and assistance that it did provide in relation to the installation of Sonoguard or that any such advice or assistance proximately caused the condition that led to Edward Crabtree's fall. Accordingly, the Court concluded the trial court correctly entered a summary judgment in favor of BASF based on the evidence before it, and the judgment of the Court of Civil Appeals was reversed. View "Crabtree v. BASF Building Systems, LLC" on Justia Law

In this case, employees sued their employer alleging breach of contract, conversion, breach of fiduciary duty, and bad faith and the application of the doctrine of estoppel arising out of the defendants' recoupment of early retirement benefits they claimed the employees were not entitled to under the employer's retirement Plan. The employer filed a counterclaim seeking immediate repayment from the employees of the benefits, interest, and attorney fees arising out of the payment of the early-retirement benefits based on their fiduciary duty to the Plan. The factual underpinnings of the adjudicated claims were the same as those of the unadjudicated counterclaim of the defendants. The trial court's resolution of the employees' claims did not moot the defendants' counterclaim because the trial court had to decide whether immediate recoupment (less any amount already received through the actuarially reduced monthly benefits), interest, and attorney fees were owed the defendants for the early-retirement benefits received by the employees. The Supreme Court remanded the case to trial court to reconsider the facts relating to the recoupment of the benefits in determining the defendants' counterclaim, including determining whether the defendants were entitled to immediate recoupment, interest, and attorney fees. The Supreme Court concluded the trial court's certification of finality under Rule 54(b) was ineffective, and, because there was no final judgment, both the appeal and cross-appeal were dismissed for lack of jurisdiction. View "Fuller v. Birmingham-Jefferson County Transit Authority" on Justia Law