Justia Alabama Supreme Court Opinion Summaries

Branson Machinery, LLC appealed a circuit court's decision that set aside a default judgment granted in its favor against Hilltop Tractor, LLC and Jeffrey Williams. According to Branson, Hilltop owed it money for equipment it had purchased. Because it had not received payment, Branson filed a breach-of-contract action against Hilltop and Mr. Williams. The Blount Circuit Court entered a default judgment in favor of Branson. Following the entry of the default judgment, Branson's counsel engaged Hilltop and Mr. Williams (acting without counsel) in settlement negotiations. The parties negotiated a "workout" agreement, and at some point, Hilltop became unable to meet the payment terms. Branson filed garnishment paperwork with the trial court seeking to enforce the original default judgment. Hilltop and Mr. Williams hired counsel and successfully moved the court to set aside the default judgment. Upon review, the Supreme Court found that the trial court exceeded its discretion in granting Hilltop and Mr. Williams' motion to set aside the default judgment. The Court reversed the trial court's decision and remanded the case to reinstate the original default judgment. View "Branson Machinery, LLC v. Hilltop Tractor, LLC" on Justia Law

Tellabs Operations, Inc. appealed an administrative agency's decision in its taxpayer's refund action from the circuit court. Tellabs unsuccessfully petitioned for a refund of allegedly overpaid sales taxes to the City of Bessemer. The case was originally filed in Montgomery Circuit Court. Bessemer filed a motion to dismiss, or in the alternative, to change venue to Jefferson Circuit Court. Without holding a hearing on the motion, the circuit court transferred the appeal to Jefferson Circuit Court. In its motion for reconsideration, Tellabs argued the Montgomery Court erred in transferring the appeal. The court responded that it had lost jurisdiction, and Tellabs' only remedy was to petition the Supreme Court. Upon review of the circuit court records, the Supreme Court concluded that the Montgomery Circuit Court erred in transferring the appeal to the Jefferson Court. The Supreme Court vacated the transfer order and remanded the case for further proceedings in Montgomery Circuit Court. View "Tellabs Operations, Inc. v. City of Bessemer " on Justia Law

Black Warrior Minerals, Inc. sued Empire Coal Sales, Inc. and John Fay, Jr. Black Warrior sought money allegedly owed pursuant to a coal-purchase agreement between Black Warrior and Empire and a personal guaranty executed by Mr. Fay. A trial court entered summary judgment in favor of Black Warrior, awarding it damages plus attorney fees and costs. The trial court held a bench trial on the breach-of-guaranty claim against Mr. Fay, entering judgment in favor of Mr. Fay. Black Warrior appealed the latter, arguing that the trial court erred in finding the language of the guaranty was ambiguous and applied only to amounts in excess of $1.2 million owed by Empire to Black Warrior. Upon review of the language of the guaranty and the applicable legal authority, the Supreme Court concluded the trial court erred in its interpretation of the guaranty's terms. The Court reversed the lower court's judgment and remanded the case for further proceedings. View "Black Warrior Minerals, Inc. v. Fay" on Justia Law

Matador Holdings, Inc. and HoPo Realty Investments, LLC filed separate appeals to challenge elements of a circuit court's order involving commercial property owned by Matador. Matador sued HoPo for payment for materials and services Matador provided to HoPo's lessee Stratford Plastic Components of Alabama. The lease agreement contained provisions allowing for HoPo or its agents to enter the property during the lease-term to make inspections or repairs. Stratford had applied for and received a line of credit with Matador. After taking possession of the leased property, Stratford ordered materials from Matador to convert the property into one suitable for Stratford's production needs. Stratford vacated the property before the lease term expired without paying Matador for the materials. HoPo's agents testified that Stratford did not request any changes be made to the leased property and had no knowledge that Matador would supply materials to the lessee. To resolve the dispute, the trial court denied Matador's claim that HoPo was unjustly enriched by the services provided to Stratford that were unpaid, but the court placed a lien on HoPo's property for the unexpired portion of the Stratford lease. Upon review of the trial court record and its order, the Supreme Court affirmed the lower court's denial of Matador's unjust enrichment claim. Furthermore, the Court reversed the lower court's order insofar as it enforced any portion of a lien against HoPo's property or the improvements made to the property. The Court ruled the lien void. View "Matador Holdings, Inc. v. HoPo Realty Investments, LLC" on Justia Law

In 2007, Massachusetts Defendant No. 1 Steel Products, Inc. (No. 1 Steel) was a subcontractor on a construction project at a health rehabilitation center in Massachusetts (Cape Regency project). While working on the project, No. 1 Steel determined that it needed to hire out some of the steel fabrication for which it was responsible. No. 1 Steel found Alabama Plaintiff Garrison Steel Fabricators, Inc. (Garrison). No. 1 Steel was dissatisfied with Garrison's work and refused to pay Garrison anything beyond what it had previously paid. In an attempt to collect the remaining amount owed, Garrison sent No. 1 Steel notice that it intended to file mechanic's liens on the project unless it was paid. Upon receiving the notice, No. 1 Steel filed a motion in Massachusetts court to discharge and release the not-yet-filed-lien, arguing that Garrison was not registered to do business in Massachusetts and that no written contract of the parties' agreement existed. The Massachusetts court granted the motion without stating a rationale. In 2009 Garrison sued No. 1 Steel in Alabama court, asserting claims of open account, implied contract and labor and work performed. No. 1 Steel moved to dismiss, arguing a lack of personal jurisdiction. Upon review of the record, the Supreme Court found the "specific contacts" No. 1 Steel had were not sufficient enough that it should have anticipated being haled into court in Alabama; No. 1 Steel's relationship with Garrison was limited to a one-time purchase of customized goods. The Court directed the trial court to dismiss Garrison's case because the court lacked personal jurisdiction over No. 1 Steel. View "Garrison Steel Fabricators, Inc. v. No. 1 Steel Products, Inc." on Justia Law

Plaintiffs James Adams, Stanley Dye and Ed Holcombe were all shareholders in Altrust Financial Services, Inc. They sued Altrust, the Peoples Bank of Alabama (collectively, Altrust) and Dixon Hughes, LLC, Altrust's public-accounting firm, for violating the Alabama Securities Act. Altrust is a holding company that fully owns, controls and directs the operations of the Bank. Altrust and the Bank share common officers and directors and issue consolidated financial statements. Shareholders voted to reorganize the company in 2008 from a publicly held company to a privately held company. The move would have freed the company of certain reporting obligations imposed by the federal Securities Exchange Act and allowed the company to elect Subchapter S status for tax purposes. Relying on information in a proxy statement, Plaintiffs elected not to sell their shares of Altrust stock and instead voted for reorganization. Plaintiffs alleged that the proxy statement and financial reports contained material misrepresentations and omissions that induced them to ultimately sign shareholder agreements that made them shareholders in the newly reorganized Altrust. Plaintiffs contended that if (in their view) instances of mismanagement, self-dealing, interested-party transactions and "skewing" of company liabilities had been fully disclosed, they would have elected to sell their shares rather than remain as shareholders. Upon review, the Supreme Court found that Plaintiffs' allegations were not specific to them but to all shareholders, and as such, they did not have standing to assert a direct action against the company. Because Plaintiffs did not have standing to assert claims against Altrust, they also lacked standing to assert professional negligence claims against the accounting firm. The Court remanded the case for further proceedings. View "Altrust Financial Services, Inc. v. Adams" on Justia Law

Petitioner Delta International Machinery Corporation (Delta) sought a writ of mandamus to direct the circuit court to vacate an order that granted Respondent Brandon Landrum access to "certain technology" in its control. Respondent was operating a portable bench saw manufactured by Delta. His hand came into contact with the sawblade and ended with injuries to his hand and amputation of his index finger. In 2007, Respondent sued Delta alleging the saw was defective and unreasonably dangerous. Though the parties agreed to a protective order which forbade certain confidential materials from being released to Respondent's expert witness who happened to be employed by one of Delta's competitors, the trial court allowed Respondent's expert to review certain technology in Delta's possession pertaining to design of safety features of the saw. The technology Respondent sought to discover had pre-dated technology that had been developed by a joint venture of all saw manufacturers, of which Delta was a part. Delta claimed that its "flesh-sensing" technology was not discoverable because it did not exist at the time Respondent's saw was manufactured, and pre-dated the joint venture. Delta objected to Respondent's discovery request as "irrelevant" and "confidential." The trial court granted Respondent's motion to inspect. Delta subsequently filed its petition to the Supreme Court. Upon review, the Supreme Court found that the flesh-sensing technology was both a trade secret and was not relevant to Respondent's claims. As such, the Court concluded that the trial court exceeded its discretion in allowing discovery of that technology and in allowing access to the technology by Delta's competitor. The Court granted Delta's request for the writ, and directed the trial court directed the trial court to vacate its order granting Respondent's motion to inspect. View "Landrum v. Delta International Machinery Corp." on Justia Law

Thomasville Feed & Seed, Inc. (Thomasville Feed) petitioned the Supreme Court for a writ of mandamus to direct the Wilcox County Circuit court to transfer the action filed against it by Roy Saulsberry and Roy Saulsberry, Jr. (The Saulsberrys) to the Clarke Circuit Court. The Saulsberrys own and operate a cattle farm in Wilcox County. Thomasville Feed is located in Clarke County. In April 2010, the Saulsberrys sued Thomasville Feed in Wilcox County Circuit Court, alleging that fertilizer they purchased from Thomasville Feed was defective and that Thomasville Feed was liable for damages under Alabama tort law. Thomasville Feed moved to dismiss the complaint, contending that Thomasville Feed only does business in Clarke County, and that Clarke County had jurisdiction over it. The trial court denied Thomasville Feed’s motion to dismiss. Thomasville Feed then filed a motion to transfer the case to Clarke County, which the trial court denied. Thomasville subsequently petitioned the Supreme Court for extraordinary relief. Upon review, the Supreme Court found that venue was proper in Clarke County. The Court vacated the Wilcox County order that denied Thomasville Feed’s motion to transfer, and issued the writ of mandamus to direct the court to transfer the case to Clarke County. View "Saulsberry v. Thomasville Feed & Seed, Inc." on Justia Law

Plaintiff Branded Trailer Sales, Inc. (Branded) appealed a circuit court judgment that dismissed its case against Universal Truckload Services for lack of personal jurisdiction. A customer contacted Branded about having some flatbed trailers designed and manufactured. Branded contacted Universal for a recommendation for companies that could do the work. Universal recommended Liddell Trailers, LLC to design and manufacture the trailers. Branded entered into a contract with Liddell. The contract provided that Universal would buy several of the specially-designed trailers from Branded. Liddell later contacted Branded that the price for each trailer would increase from their previously-agreed cost, and that it would take longer for the components to be assembled. Branded would later learn that Universal negotiated a deal directly with Liddell to provide the same trailers at a lower price, excluding Branded from the agreement. Branded filed suit alleging that Universal and Liddell had intentionally interfered with the Branded-Liddell contract. Upon review, the Supreme Court found sufficient evidence that Branded made detailed assertions regarding its theories of personal jurisdiction, and the record reflected Branded presented that evidence to support those assertions. Therefore, the Court found that the trial court exceeded its discretion when it granted Universal's motion to dismiss. The Court reversed the trial court's judgment and remanded the case for further proceedings. View "Branded Trailer Sales, Inc. v. Universal Truckload Services, Inc." on Justia Law

Nationwide Mutual Insurance Company (Nationwide) appealed a trial court’s order that denied its "renewed motion for a judgment as a matter of law" in its case against J-Mar Machine & Pump. J-Mar is a repair shop that held a commercial liability and property insurance policy with Nationwide. In 2004, in anticipation of its policy renewal, Nationwide sent an inspector to the shop. In his report, the inspector noted several safety hazards and a messy shop. The insurance policy was renewed in March but several months later Nationwide cancelled the policy. Nationwide cited the inspector’s report as reason for the cancellation. J-Mar management was not aware of the cancellation until late that year when shop property was stolen. When it tried to file a claim, Nationwide declined J-Mar’s claim. A jury trial was held on the disputed policy cancellation and coverage. At the close of J-Mar’s case, Nationwide moved the court for a "judgment as a matter of law" which was denied. Nationwide unsuccessfully motioned again at the close of all evidence. Upon review of the trial court record, the Supreme Court found that the evidence J-Mar presented at trial was insufficient to support the jury verdict in its favor. Accordingly, the Court reversed the trial court’s judgment denying Nationwide’s motion and rendered a judgment in Nationwide’s favor. View "Nationwide Mutual Ins. Co. v. J-Mar Machine & Pump, Inc." on Justia Law