Justia Alabama Supreme Court Opinion Summaries

Defendant Brandon Mitchell was convicted on four counts of capital murder for killing three people during the course of a robbery at a hotel. The jury recommended that Defendant be sentenced to life in prison without the possibility of parol on each conviction. After considering Defendant's presentence report and holding a sentencing hearing, the trial court overrode the jury's recommendation and sentenced Defendant to death. The Court of Criminal Appeals affirmed. Defendant petitioned the Supreme COurt for a writ of certiorari to review the decision of the appellate court, asserting seventeen separate grounds for review. The Court granted the writ in May 2011, and issued the writ to examine the sole question on whether the trial court complied with Ala. Code 1975 section 13A-5-47(d) and (e). Upon receiving the record, the Court determined the writ was "improvidently issued" and quashed it. The Court found that the trial court fully complied with Alabama Code. View "Mitchell v. Alabama " on Justia Law

This appeal was the latest "in a decade-long dispute" between Joseph Dzwonkowski, Sr. (Joe Sr.) and two of his sons, Robert and Joseph Jr. (Joe Jr.) regarding the ownership and control of Sonitrol of Mobile, Inc., a closely-held corporation that provided commercial-security services in the greater Mobile area. Ten years prior, Joe Jr. sold his shares in the company to his father in order to settle some of his personal debts. Possession of the stock certificates was the central issue in the case. Joe Sr. fired his sons and offered to purchase their shares, but Joe Jr. demanded his former shares back from his father. Joe Sr. then filed suit for a declaratory judgment to determine who rightfully owned the stock and to uphold his decision to fire his sons. The trial court ruled against Joe Sr. In 2004, the Supreme Court dismissed Joe Sr.'s appeal of that judgment, holding that an appeal was premature because the damages to be awarded to Sonitrol had not yet been set. Those damages were eventually set in 2011, awarding Sonitrol $764,359 and Joe Jr. $1. Joe Sr. appealed. On appeal, Joe Sr. argued whether the trial court should have immediately entered an order declaring him owner of the disputed shares of Sonitrol stock. The Supreme Court found that the trial court did not act contrary to the appellate court's mandate on remand. Accordingly the trial court's judgment was affirmed. View "Dzwonkowski v. Sonitrol of Mobile, Inc." on Justia Law

Defendants/Counterclaim Plaintiffs Charles Stephens and Stephens Properties, Inc. appealed a judgment entered on a jury verdict in favor of Fines Recycling, Inc. and its shareholders on claims stemming from a dispute over a commercial lease. Fines operated an scrap metal recycling business on Stephens' property. The State sent Fines a notice that it was illegally operating a solid waste dump on the property, and demanded the company cease operations until the waste was cleaned up. The shareholders pledged their stock to Stephens Properties as security for Fines' obligation to clean up the property. Following the completion of the cleanup, Stephens allegedly failed to return the stock certificates pledged by the Fines shareholders. The shareholders sued for the stocks' return; Stephens responded that the stock was subsequently used as a setoff for payment of back rent and other expenses relating to the cleanup. Upon review, the Supreme Court found that the trial court purported to certify its judgment as final, but that there were still pending counterclaims active in the case. The Court concluded that "the judgment on the jury verdict was not a final judgment, and, because of the nature of the pending issues, could not be transformed into a final judgment by a [final] certification." The Court reversed the trial court's certification and remanded the case for further proceedings. View "Stephens v. Fines Recycling, Inc." on Justia Law

Petitioner Andrew Sutley petitioned the Supreme Court for a writ of mandamus to direct the Court of Civil Appeals to quash a May 2011 writ. In its opinion, the appellate court directed the Montgomery Circuit Court to vacate its December 2010 order that added the Alabama State Personnel Board as a party to Petitioner's administrative appeal. The underlying matter arose from Petitioner's dismissal from his job as an Alabama State Trooper. Petitioner moved to add the Board as respondent to his appeal at the circuit court. The circuit court granted that motion five months after the Board entered its final order upholding Petitioner's dismissal. The Board then petitioned the Court of Civil Appeals for a writ of mandamus to order the circuit court to dismiss Petitioner's case as untimely. Upon its review of the record, the Supreme Court found Petitioner did not have a clear legal right to a writ of mandamus to direct the appellate court to quash its writ of mandamus. Accordingly, the Supreme Court denied his petition. View "Sutley v. Alabama Dept. of Pub. Safety " on Justia Law

Employers Mutual Casualty Company (Employers Mutual) appealed a circuit court's denial of its motion to intervene in a pending case. Holman Building Company was sued by multiple homeowners who claimed their homes were poorly built from inferior building materials with poor quality workmanship. In 2010, Employers Mutual moved to intervene in the action, asserting that it had issued Holman commercial general-liability and umbrella policies that covered some if not all of the allegations made by the homeowners. Upon review, the Supreme Court held that the trial court did not abuse its discretion in denying Employers Mutual's permissive intervention: "given the complexity of this case, the trial court was clearly within ints discretion to deny Employers Mutual's request to intervene for the purpose of obtaining a bifurcated trial of insurance-coverage issues or a special verdict or a general verdict accompanied by answers to interrogatories ... this case provides a prime example of the need for discretion in a trial court's ruling on an insurer's motion for permissive intervention." Accordingly, the Court affirmed the trial court's decision to deny the insurance company's intervention. View "Employers Mutual Casualty Company v. Holman Building Co., LLC et al. " on Justia Law

Defendant James Beauford Lamb, Jr. appealed the Court of Criminal Appeals' affirmance of his 2004 conviction for first-degree sexual abuse. The issue on appeal was whether the trial court erred in entering a judgment based on an amended written jury verdict that differed from one taken from a direct poll of the jury after it had been discharged from its duty. Alabama case law held that once a jury had been discharged and "left the court's control, the jury could not properly be resummoned to correct or amend an insufficient verdict, and that the judgment entered on the amended verdict of that recalled jury must be reversed." Following precedent, the Supreme Court concluded that the amended verdict would constitute double jeopardy. Accordingly, the Court reversed the appellate court's affirmance of the amended verdict and remanded the case for further proceedings. View "Lamb v. Alabama" on Justia Law

Defendant T.D.M. was convicted on one count of first degree sexual abuse and one count of first degree sodomy. At the end of Defendant's trial, the jury first returned verdicts of guilty and not guilty, respectively. The jury was then discharged. The clerk of the court informed the trial judge that due to a clerical error, the 'not-guilty' verdict was entered incorrectly. The jury was recalled, and each juror polled stated that he/she had voted Defendant guilty on the sodomy charge. Ultimately the trial court entered a corrected judgment finding Defendant guilty on the sodomy charge, and passed sentence accordingly. Defendant unsuccessfully appealed the convictions. The issue before the Supreme Court was whether Defendant's constitutional rights against double jeopardy had been violated by the poll of the jury and change in Defendant's sentence. Upon review, the Supreme Court found that under the circumstances of this case, Defendant's constitutional rights were violated. The Court reversed the sodomy conviction and remanded the case for further proceedings. View "T. D. M. v. Alabama " on Justia Law

Defendant Mitzi Lawson appealed a judgment in favor of Plaintiffs Harris Culinary Enterprises, LLC (HCE), John C. Harris III (Clinton), and John C. Harris, Jr. (John), (collectively "the Harrises"), on their fraud claims related to their purchase of a restaurant franchise. Mitzi was married to codefendant, Sims Lawson. Following his marriage to Mitzi, Sims formed SYM, Inc. for the purpose of operating a "Fox's Pizza Den" restaurant franchise in Killen. Sims purchased a building in which to operate the franchise; that building was titled solely in Mitzi's name. At some time before the events giving rise to their claims on appeal, John and Clinton formed HCE for the purpose of operating pizza-restaurant franchises. In March 2007, the Harrises entered into negotiations with Sims to purchase the Killen franchise. According to the Harrises, in an apparent attempt to secure a higher purchase price, Sims purportedly generated false financial reports evidencing higher gross sales and profits for the Killen franchise than were actually realized. The Harrises ultimately purchased the Killen franchise. As a condition of the sales agreement, the Harrises entered into a one-year lease agreement to continue operation of the Killen franchise in its then current location. The Harrisses initiated the underlying lawsuit alleging that as a result of the allegedly falsified financial reports, they were induced to purchase both the franchise and enter into the lease agreement. Mitzi moved to dismiss the claims against her, arguing that she made no actual representation to the Harrises. Plaintiffs won at trial, and Mitzi appealed. Upon review, the Supreme Court found that there was no evidence presented at trial from which the court could have reasonably determined that Mitzi made any misrepresentation to the Harrises. Accordingly, the Court reversed the trial court's judgment against her. View "Lawson v. Harris Culinary Enterprises, LLC" on Justia Law

Defendants the Colbert County Board of Education ("the Board"); and the individual members of the Board and members of the Colbert County High School appealed a trial court's judgment that granted Plaintiff Felecia James's motion for a preliminary injunction. On or about May 21, 2010, an incident occurred at Colbert County High School (CCHS) involving J.H., Plaintiff's minor child, and another minor enrolled in CCHS. The details of the incident were disputed, but they led the assistant principal of the school to suspend both students for three days for allegedly fighting on school property during school hours. Plaintiff appeared before the Board to discuss the situation. The Board apparently took no action, and Plaintiff "individually and as mother and guardian of J.H." sued the Board and the individually named defendants asserting state-law and federal-law claims She also filed a motion for a temporary restraining order, a preliminary injunction, and a permanent injunction. Upon review, the Supreme Court found that the Board members in their official capacities were immune from the state-law claims filed against them insofar as those claims sought monetary damages. As such, the trial court lacked subject-matter jurisdiction over those state-law claims against the officials in their official capacities. However, the Board members were not immune from Plaintiff's state-law claims insofar as she sought injunctive relief based upon the Board members' alleged fraud, bad faith, or actions that were beyond the Board members' authority or that were taken under a mistaken interpretation of law. The Court noted that the Board and its members were not immune from the federal-law claims filed against them. Based on the foregoing, insofar as the Board appealed the preliminary injunction against it based upon the state-law claims filed by Plaintiff, the Supreme Court dismissed their appeal for lack of subject-matter jurisdiction. Because the Court reversed the preliminary injunction, the Court declined to order the trial court to vacate the preliminary injunction entered against the Board insofar as it was based on those claims. View "Colbert Cty. Bd. of Edu. v. James" on Justia Law

The State petitioned the Supreme Court for a writ of certiorari to review the Court of Criminal Appeals' decision to reverse Sean Travis Howard's criminal conviction based on the trial court's failure to charge the jury on manslaughter as a lesser offense to capital murder, the offense with which Howard was charged. The Court granted review to consider whether the Court of Criminal Appeals' decision conflicted with its decision in "Fox v. State." The Court concluded that it did, and reversed the Court of Criminal Appeals' judgment: "Reckless murder and reckless manslaughter do not involve the same degree of recklessness. … [t]he difference between the circumstances which will support a murder conviction and the degree of risk contemplated by the manslaughter statute is one of degree, not kind. ... [T]he degree of recklessness which will support a manslaughter conviction involves a circumstance which is a 'gross deviation from the standard of conduct that a law-abiding person would observe in the actor's situation,' but is not so high that it cannot be 'fairly distinguished from' the mental state required in intentional homicides." Accordingly, the Court reversed the Court of Criminal Appeals and remanded the case for further proceedings. View "Howard v. Alabama" on Justia Law