Justia Alabama Supreme Court Opinion Summaries

Christopher Ellis worked for CSX Transportation, Inc. as a remote-control foreman at CSX's Montgomery yard. While riding on the ladder of a railcar during the course of his employment with CSX, Ellis was struck in the torso by the broken door handle and latch assembly of a railcar on an adjacent track. The impact of the blow knocked Ellis off the railcar on which he was riding, causing him to suffer significant injuries. On November 17, 2020, Ellis sued CSX asserting claims under the Federal Employers' Liability Act ("FELA"), and the Safety Appliance Act ("the SAA"). Ellis propounded 25 multipart interrogatories and 62 requests for production to CSX with his complaint. CSX petitioned the Alabama Supreme Court for a writ of mandamus directing the Montgomery Circuit Court to, among other things, vacate its order granting Ellis's motion to compel discovery and either enter an order denying Ellis's motion to compel or a protective order barring production of materials CSX contends to be protected work product or patently irrelevant. The Supreme Court granted the petition for mandamus relief in part and directed the trial court to vacate its order to the extent that it requires the production of materials contained in the company's risk management system ("RMS") in violation of the work-product doctrine. The Court denied the petition in all other respects. View "Ex parte CSX Transportation, Inc." on Justia Law

Plaintiffs Cathedral of Faith Baptist Church, Inc., and Lee Riggins appealed a circuit court judgment dismissing their complaint against defendants Donald Moulton, Sr. and Broken Vessel United Church on grounds that the claims asserted in the complaint were barred by the applicable statute of limitations. Riggins was a stockholder and the chairman of the board of Cathedral of Faith Baptist Church, Inc. ("Cathedral"), which owned property located in Birmingham where it operated Cathedral Church. Worship services were conducted at Cathedral Church until the Church's membership dwindled and its services were discontinued; legal title to the Cathedral Church property ultimately vested in Riggins. In 2014, Riggins leased the Cathedral Church property to Moulton, the pastor of Broken Vessel United Church. Moulton and Broken Vessel agreed to pay the commercial-liability insurance that Cathedral maintained with Planter's Insurance. In July 2016, Moulton and Broken Vessel changed the insurance carrier from Planter's Insurance to Nationwide Mutual Insurance Company without Cathedral and Riggins's knowledge or consent. The application for insurance that Moulton submitted to Nationwide contained multiple false statements. On November 26, 2016, Cathedral Church was destroyed by a fire. Moulton made a claim to Nationwide regarding the Cathedral Church property and its contents. In August 2017, Riggins discovered a "property settlement with Nationwide." Riggins subsequently discovered both a general warranty deed, dated January 1, 2012,1 that had been filed in the Jefferson County Tax Assessor's office on January 16, 2015, purporting to convey title to Cathedral Church from Riggins to Broken Vessel for $150,000, as well as a corrected deed that had been filed in January 2018. Deficiencies existed on the face of both the original warranty deed and the corrected deed. The trial court ultimately entered an order dismissing the claims against defendants. The Alabama Supreme Court reversed, finding the complaint was filed within the 10-year limitations period set forth by the applicable statute. View "Cathedral of Faith Baptist Church v. Moulton, et al." on Justia Law

Gwendolyn Barnett appealed orders granting relief to Robert Lee Hull, Jr. Barnett and Hull are siblings and the sole legal heirs of their father, Robert Lee Hull, Sr. ("Robert"), who died testate. Pursuant to Robert's will, Hull and Barnett were listed as beneficiaries entitled to equal shares of his estate and Barnett was named personal representative of his estate. Hull filed a complaint against Barnett, arguing that in her role as "a partial caretaker of [Robert]" before his death, had exerted undue influence over Robert and had gained control of Robert's personal property and assets. According to Hull, in the absence of Barnett's purported misconduct, items that Barnett allegedly misappropriated would "have become part of [Robert's] estate." Barnett moved ti dismiss her brother's tort action, claiming that Hull's complaint in the tort action realleged claims purportedly "identical" to claims that Hull had previously asserted in the estate administration, which had been dismissed. The trial court granted Hull's motion in full and denied Barnett's motion to dismiss. On appeal, among other things, Barnett contended the trial court lacked jurisdiction over Hull's claims in the tort action, which she described as "central to the administration of the estate," while the estate administration remained separately pending. In her filings to the Supreme Court, Barnett characterized Hull's claims as "seek[ing] to identify property which he alleges should have been considered property of the Estate ... in the [first-filed] estate administration." To this, the Alabama Supreme Court agreed. Therefore, the trial court lacked jurisdiction over matters relating to the pending estate administration, and lacked jurisdiction to enter the the injunctive order or the subsequent show-cause order compelling Barnett's compliance with the injunctive order. The Supreme Court thus reversed all orders entered by the trial court in the tort action and remanded the matter for that court to enter an order dismissing Hull's complaint. View "Barnett v. Hull" on Justia Law

Premier Plastic Surgery, P.C. ("Premier") petitioned the Alabama Supreme Court for a writ of mandamus directing the Jefferson Circuit Court to vacate its order denying Premier's motion for a change of venue in this medical-malpractice action brought by plaintiff Deborah Bush, and to enter an order transferring the action to the Shelby Circuit Court. Premier offered cosmetic and reconstructive surgery at its medical facility located in Shelby County. Bush went to Premier's medical facility to receive a consultation from Dr. Peter Van Hoy. It is undisputed that all of Bush's treatment by Dr. Van Hoy occurred at Premier's medical facility. In December 2017, Dr. Van Hoy died. Because he was Premier's sole shareholder, director, and owner, Premier was dissolved in September 2018. In June 2019, Bush filed suit at the Jefferson Circuit Court relating to her surgical procedure and treatment by Dr. Van Hoy. Bush's complaint also alleged that she was a resident of Jefferson County. Premier denied all allegations and argued that because the surgical procedure and treatment at issue in Bush's action occurred at Premier's medical facility in Shelby County, venue was proper in Shelby County. In her response to Premier's motion, Bush did not dispute that Shelby County was the proper venue for the action. Instead, she argued that because Premier's motion was filed almost three years after the litigation began and only three weeks before the scheduled trial, the motion cannot be deemed timely. The Supreme Court concurred that Premier's challenge to venue had been waived and denied the petition for mandamus relief. View "Ex parte Premier Plastic Surgery, P.C." on Justia Law

Charles Edward Rainwater, Jean Rainwater Loggins, The Lem Harris Rainwater Family Trust, and the Rainwater Marital Trust appealed a circuit court's final judgment enforcing a settlement agreement in the litigation involving four siblings and the family trusts. They challenged three aspects of the judgment: its enforcement of the settlement agreement, its denial of a motion to dissolve a prior order enforcing the settlement agreement, and its denial of a motion to quash a garnishment. Because the court failed to hold an evidentiary hearing on enforcement of the settlement agreement, because the prior enforcement order was improper, and because any award on which the garnishment could have been based was being reversed, the Alabama Supreme Court reversed the judgment as to all three aspects. View "The Lem Harris Rainwater Family Trust, et al. v. Rainwater" on Justia Law

In 2017, the State of Alabama sued, among others, Epic Tech, LLC ("Epic Tech"); K.C. Economic Development, LLC, d/b/a VictoryLand ("KCED"); and Sheriff Andre Brunson, in his official capacity as sheriff of Macon County (referred to collectively as "the Macon County defendants"). At around that same time, the State sued, White Hall Enrichment Advancement Team d/b/a Southern Star Entertainment ("Southern Star") and White Hall (referred to collectively as "the Lowndes County defendants"). In each action, the State sought an order declaring the illegal gambling operations conducted by the defendants to be a public nuisance and related injunctive relief. The State's complaint in each action was also accompanied by a motion seeking the entry of an order preliminarily enjoining the defendants from engaging in illegal gambling operations. In case nos. 1200798 and 1210064, the State appealed Macon Circuit Court and Lowndes Circuit Court orders denying the State's requests for injunctive relief. In case no. 1210122, defendants/counterclaim plaintiffs White Hall Entertainment and the White Hall Town Council (referred to collectively as "White Hall"), cross-appealed the Lowndes Circuit Court's order dismissing their counterclaims against the State. The Alabama Supreme Court consolidated these appeals. In case no. 1200798, the Court reversed the Macon Circuit Court order denying the State's request for preliminary injunctive relief and remanded the matter for that court to enter, within 30 days, a preliminary injunction enjoining the defendants' gambling operations in Macon County; in case no. 1210064, the Court reversed the Lowndes Circuit Court order denying the State's request for permanent injunctive relief and remanded the matter for that court to enter, within 30 days, a permanent injunction enjoining the defendants' gambling operations in Lowndes County; and in case no. 1210122, the Court affirmed the Lowndes Circuit Court's order dismissing White Hall's counterclaims. View "White Hall Entertainment, et al. v. Alabama" on Justia Law

American Cast Iron Pipe Company ("ACIPCO") petitioned the Alabama Supreme Court to review the Court of Civil Appeals' decision to reverse a circuit court's dismissal of a workers' compensation action. Suit was filed by Karene Stricklin against ACIPCO who alleged her ward and conservatee, John Gray, sustained injuries while an ACIPCO employee. The Supreme Court granted the petition to consider, as a matter of first impression, whether Article II of the Alabama Workers' Compensation Act ("the ombudsman-program article"), which encompassed § 25-5-290 through § 25-5-294, Ala. Code 1975, precluded an action seeking to have a benefit-review agreement declared void ab initio on the basis of a signatory's mental incompetency when that action was not commenced so as to comply with the 60-day period set forth in § 25-5-292(b), Ala. Code 1975. To this, the Court concluded that it did not, and, thus, affirmed the Court of Civil Appeals' decision. View "Ex parte American Cast Iron Pipe Company." on Justia Law

Plaintiffs Cathedral of Faith Baptist Church, Inc., and Lee Riggins appealed a circuit court judgment dismissing their complaint against Donald Moulton, Sr., and Broken Vessel United Church ("the Broken Vessel defendants") pursuant to Rule 12(b)(6), Ala. R. Civ. P., on the basis that the claims asserted in the complaint against the Broken Vessel defendants are barred by the applicable statute of limitations. The Alabama Supreme Court determined the allegations of the complaint, when construed in plaintiffs' favor, were sufficient to sate a claim for a declaratory judgment. Further, the Court found the trial court erred in dismissing count one of the complaint against the Broken Vessel defendants on the basis that it was barred by the applicable statute of limitations. The case was remanded for further proceedings. View "Watkins v. Matrix, LLC, et al." on Justia Law

Robert Owen died 11 days after being transferred from Huntsville Hospital to the University of Alabama at Birmingham Hospital ("UAB Hospital") for cardiac treatment. His widow Gloria Owen, as the personal representative of his estate, sued the ambulance company that had transported him, Huntsville Emergency Medical Services, Inc. ("HEMSI"), as well as HEMSI employees Jacob Steele, Calvin Hui, Christopher Nunley, and Dea Calce, alleging that events that occurred during Robert's transport had "caused him unnecessary stress, worry, concern, anxiety, and/or a delay in treatment," leading to further heart damage and his eventual death. During discovery, Gloria sought information from the HEMSI defendants about the previous conduct and employment record of Steele, a licensed emergency medical technician ("EMT") and the assigned driver of the HEMSI ambulance that transported Robert. The HEMSI defendants objected to Gloria's requests and sought a protective order, arguing that the Alabama Medical Liability Act ("the AMLA") governed her claims and prohibited discovery related to any acts and omissions of a defendant that were not specifically described in the complaint. The circuit court rejected the HEMSI defendants' request for a protective order and directed them to produce the requested discovery; they petitioned the Alabama Supreme Court for mandamus relief, specifically a writ directing the trial court to amend its order to give effect to what they claimed were the applicable privilege and discovery protections of the AMLA. The Supreme Court granted the petition in part, and denied in part. The Court held all claims asserted by Gloria in this action were governed by the AMLA and subject to the limitations on discovery imposed by § 6-5-551. To the extent that the trial court's October 2021 order did not give effect to the § 6-5-551 privilege, the HEMSI defendants' petition was granted and the trial court was directed to modify that order. But to the extent the HEMSI defendants sought to prevent Gloria from discovering information regarding acts or omissions that were specifically alleged and described in her complaint, their petition was denied. View "Ex parte Huntsville Emergency Medical Services, Inc., et al." on Justia Law

Gwendolyn Barnett and Robert Lee Hull, Jr. were siblings and the sole legal heirs of their father, Robert Lee Hull, Sr. ("Robert"), who died testate. Pursuant to Robert's will, Hull and Barnett were listed as beneficiaries entitled to equal shares of his estate and Barnett was named personal representative of his estate. In August 2019, Barnett obtained letters testamentary from the Probate Court. The administration of Robert's estate ("the estate administration") was later removed to the Circuit Court and assigned case no. CV-19-900322 following Hull's filing of a verified petition for removal. While the estate administration continued, Hull commenced the underlying action, a separate civil action against Barnett in the Circuit Court ("the tort action"), which was assigned case no. CV-20- 900192. Hull's complaint in the tort action alleged that Barnett, in her role as "a partial caretaker of [Robert]" before his death, had exerted undue influence over Robert and had gained control of Robert's personal property and assets. According to Hull, in the absence of Barnett's purported misconduct, items that Barnett allegedly misappropriated would "have become part of [Robert's] estate." Among other relief, Hull sought the imposition of a constructive trust "in an effort to avoid [Barnett's] further unjust enrichment." Barnett filed a motion seeking to dismiss the tort action. In her motion, Barnett asserted that Hull's complaint in the tort action realleged claims purportedly "identical" to claims that Hull had previously asserted in the estate administration, which had been dismissed. The trial court in the tort action entered an order granting Hull's motion in full. Barrett appealed, arguing the trial court lacked jurisdiction over Hull's claims. The Alabama Supreme Court concurred the trial court lacked jurisdiction over matters relating to the pending estate administration. It reversed all orders entered by the trial court in the tort action, and remanded for that court to enter an order dismissing Hull's complaint. View "Barnett v. Hull" on Justia Law