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

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

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

Shirley R. Hulsey and her husband purchased a residence in Tuscaloosa, Alabama, which was adjacent to a vacant lot owned by Yellow Hammer Capital Management, LLC. In 2017, Build Art, LLC was retained by Yellow Hammer to construct a residence on the adjacent lot, which was at a higher elevation and sloped toward Hulsey’s property. After construction began, Hulsey observed water and debris flooding her property, which she attributed to changes in the grading and runoff from the construction. She alleged that the construction caused damage to her home’s foundation and sought damages and injunctive relief against Build Art, Yellow Hammer, and unnamed defendants, claiming trespass, nuisance, negligence, wantonness, emotional distress, and violation of her common-law rights concerning surface water flow.The Tuscaloosa Circuit Court granted summary judgment in favor of Build Art on all claims against it, while the claims against Yellow Hammer and other defendants remained pending. Hulsey moved for reconsideration, which was denied. The court subsequently certified the summary judgment as final under Rule 54(b) of the Alabama Rules of Civil Procedure, allowing Hulsey to file an appeal to the Supreme Court of Alabama.The Supreme Court of Alabama reviewed whether the trial court’s order was a final judgment suitable for appeal. The Supreme Court determined that the claims against Build Art and Yellow Hammer were so closely intertwined, arising from the same operative facts, that certifying the summary judgment as final was improper. The Supreme Court held that such certification posed risks of inconsistent results and wasted judicial resources. Consequently, the Supreme Court dismissed the appeal, finding that the order was not a final judgment capable of supporting appellate review. View "Hulsey v. Build Art, LLC" on Justia Law

A mother and father, previously divorced, shared joint custody of their minor son. While visiting his father’s home, the child wandered into a neighbor’s property, accessed a swimming pool, and drowned. Following the child’s death, the mother—on behalf of her son—filed a wrongful death suit against both the father and the neighbor. The father cross-claimed against the neighbor for wrongful death as well. The neighbor settled with both parents, and the settlement funds were interpleaded with the Jefferson Circuit Court, Bessemer Division, which then dismissed all claims against the neighbor.After the neighbor’s dismissal, the mother received half of the settlement funds. The father’s portion was held by the court pending resolution of a related criminal case, in which the father later pleaded guilty to criminally negligent homicide. The mother then requested that the court award her the remainder of the funds, arguing that Alabama law and public policy prohibited the father from benefitting financially from his son’s death. The father argued that because his conviction did not involve a felonious and intentional killing, he was not barred from recovery. The trial court agreed with the father and ordered the remaining funds to be disbursed to him, while reserving all other issues for trial or further hearing.Upon appeal, the Supreme Court of Alabama reviewed the case. The Court held that it lacked jurisdiction because the order appealed from was not a final judgment. The trial court had expressly reserved remaining claims—specifically, the wrongful death claim against the father—so not all issues between all parties had been conclusively resolved. The Supreme Court of Alabama therefore dismissed the appeal. View "B.S.H. v. Humphryes" on Justia Law

In this matter, a member of the University of Alabama’s men’s basketball team, Kai Spears, brought suit against The New York Times Company after it published articles erroneously identifying him as the unidentified passenger in a car at the scene of a high-profile shooting. The Times based its reporting on information from two confidential sources. Spears, who was not in the car, alleges that The Times failed to use reasonable care in publishing false and damaging statements about him. During litigation in the United States District Court for the Northern District of Alabama, Spears sought discovery to uncover the identities of the sources and related information. The Times resisted, invoking Alabama’s “shield statute,” which protects journalists from being compelled to reveal confidential sources.The United States District Court for the Northern District of Alabama certified two questions to the Supreme Court of Alabama concerning the scope of the state’s shield statute. The first question asked whether the statute protects the identity of a source when information is published online. However, as Spears conceded that the print publication of the article triggered the statute’s application, the Supreme Court of Alabama declined to answer this question, finding it irrelevant to the case.The Supreme Court of Alabama addressed the second certified question, which asked whether the shield statute protects any and all information that could reasonably lead to the identification of a protected source. The Court held that Alabama’s shield statute does not extend so broadly. Instead, it protects only information that would inevitably reveal the identity of a confidential source. Thus, information that could merely “reasonably lead” to the identification of a source is not covered. The Court declined to expand the statute’s protections beyond its plain language and expressly limited the privilege to “source-identifying” information whose disclosure would make identifying the source unavoidable. View "The New York Times Company v. Spears" on Justia Law

The dispute arose from a contract signed on May 12, 2021, under which Kindra Cooper agreed to purchase a house from Highland Rim Investments, LLC. Delays in closing led the parties to enter into three extensions, but the sale never concluded. Cooper then sued for specific performance, declaratory judgment, and damages, later amending her complaint to add additional defendants and claims, including various forms of misrepresentation and a request to pierce Highland Rim’s corporate veil. During litigation, certain claims were dismissed, and after a jury trial, the jury awarded Cooper compensatory and punitive damages against Highland Rim and Monique Dollone, but found for other defendants on the misrepresentation claims.The Madison Circuit Court entered judgment on the jury's verdict, awarded Cooper attorney fees, granted her motion to pierce the corporate veil as to one defendant, and later appointed a receiver over Highland Rim to preserve its fiscal health until the judgment was satisfied. The defendants moved for post-judgment relief, which was denied, and then appealed both the judgment and the receivership order.The Supreme Court of Alabama reviewed the appeals. It found that the trial court erred by requiring the parties to strike the jury from a list of only 21 prospective jurors, rather than the 24 required by Alabama Rule of Civil Procedure 47(b). This procedural error mandated reversal. The Supreme Court of Alabama held that the trial court’s judgment in favor of Cooper and its order appointing a receiver over Highland Rim must be reversed. The cases were remanded for further proceedings consistent with this opinion. View "Highland Rim Investments, LLC v. Cooper" on Justia Law

A woman sought to challenge the probate of a will and asserted claims seeking recognition as an heir, either as a biological child or by equitable adoption, following the death of a decedent who resided in Tallapoosa County. After letters of administration had initially been issued to her by the Montgomery Probate Court, subsequent proceedings transferred jurisdiction to the Tallapoosa Probate Court, which admitted a document as the decedent’s will and appointed other individuals as personal representatives. The woman then filed a pro se complaint in the Tallapoosa Circuit Court, contesting the will and requesting various relief, including a DNA test to establish her relationship to the decedent.The Tallapoosa Circuit Court held a hearing, denied her request to compel DNA testing of the proponents, allowed her to submit her own certified DNA evidence, and later dismissed the action on the ground that she had failed to provide proof of relationship as required. She appealed to the Alabama Court of Civil Appeals, which transferred the appeal to the Supreme Court of Alabama due to jurisdictional reasons.The Supreme Court of Alabama determined that, due to statutory changes enacted by Act No. 2022-427, original jurisdiction for will contests relating to wills filed for probate on or after January 1, 2023, lies with the probate court, not the circuit court, except in cases where a proceeding has been properly removed to the circuit court. Finding that no removal had occurred, the Supreme Court held that the circuit court lacked subject-matter jurisdiction over the will contest. The Court reversed the circuit court’s judgment and remanded the case with instructions to dismiss the action for lack of subject-matter jurisdiction. The Supreme Court made no determination as to the woman’s ability to bring a will contest in the probate court. View "Glenn v. Caldwell" on Justia Law

Tara Grall and her former husband, William Grall, were the sole shareholders of G-Team, P.C., an Alabama professional corporation that had ceased business operations. Amid their divorce proceedings, William initiated a derivative action against Tara, seeking to enforce the corporation's right to sell its real property to pay off mortgage debt. Tara argued that the property could not be sold due to an existing Small Business Administration lien. The trial court ordered the sale of the property and scheduled a hearing to determine the distribution of proceeds and finalize the winding up of G-Team. Tara, representing herself, filed multiple motions, including requests to stay hearings, appear remotely, and recuse the judge, but these were denied.Tara appealed several interlocutory orders to the Alabama Court of Civil Appeals, describing her appeal as interlocutory and requesting a stay, which was denied. Despite her pending appeal, the trial court conducted a final hearing and entered a purported final judgment on May 1, 2025, winding up G-Team. Tara then appealed that judgment as well. The Court of Civil Appeals transferred both appeals to the Supreme Court of Alabama, citing a lack of subject-matter jurisdiction.The Supreme Court of Alabama determined it lacked jurisdiction over both appeals. It held that the first appeal was not from a final judgment nor from an appealable interlocutory order under Rule 4(a)(1), Alabama Rules of Appellate Procedure, and therefore must be dismissed. The second appeal was from a judgment entered while the first appeal was pending, at which point the trial court was divested of jurisdiction; this made the subsequent judgment void and the second appeal also subject to dismissal. Both appeals were dismissed by the Supreme Court of Alabama. View "Grall v. Grall" on Justia Law