Justia Alabama Supreme Court Opinion Summaries

In August 2022, Rebecca Henderson and her minor son were involved in an automobile collision in Alabama. Henderson, a Kentucky resident, had an insurance policy from Kentucky Farm Bureau Mutual Insurance Company (Kentucky Farm Bureau) that provided uninsured-motorist (UM) benefits. In July 2024, Henderson filed a complaint in the Baldwin Circuit Court, asserting a negligence/wantonness claim against the other driver, Trey Allan Knapp, and a claim for damages by contract against Kentucky Farm Bureau, alleging entitlement to UM benefits as Knapp had no liability insurance.Kentucky Farm Bureau moved to dismiss the claim, arguing that the Baldwin Circuit Court lacked personal jurisdiction over it, as it only does business in Kentucky and has no contacts with Alabama. The motion was supported by an affidavit from a Kentucky Farm Bureau employee. Henderson opposed the motion, arguing that the insurance policy provided nationwide coverage, thus establishing sufficient contacts with Alabama. The circuit court denied the motion to dismiss without explanation, leading Kentucky Farm Bureau to petition the Supreme Court of Alabama for a writ of mandamus.The Supreme Court of Alabama reviewed the case and concluded that Kentucky Farm Bureau did not have sufficient contacts with Alabama to establish personal jurisdiction. The court noted that the insurance policy was issued and delivered in Kentucky, and Kentucky Farm Bureau does not conduct business in Alabama. The court distinguished between providing liability coverage nationwide and being subject to contract claims in any state. Consequently, the court granted the petition and issued a writ of mandamus directing the Baldwin Circuit Court to dismiss Henderson's claim against Kentucky Farm Bureau for lack of personal jurisdiction. View "In re: Henderson v. Kentucky Farm Bureau Mutual Insurance Company" on Justia Law

Earnest Charles Jones was severely injured by a bull on August 27, 2018, and was transported by helicopter to the University of South Alabama Hospital. During the transport, flight nurse Bryan Heath Wester allegedly removed a nasal-gastro tube from Jones's throat, causing further injuries. Nearly two years later, Ovetta Jones, on behalf of Earnest, filed a lawsuit against Wester and Air Evac EMS, Inc., alleging negligence and wantonness related to the care provided during the transport.The Dallas Circuit Court initially reviewed the case, where the Joneses filed their complaint on August 24, 2020. The complaint focused on the removal of the nasal-gastro tube by Wester. Nearly four years later, the Joneses amended their complaint to include new allegations that Wester had stolen and replaced ketamine with saline solution the day before the transport, and that other flight nurses failed to detect this and properly treat Earnest's pain. Air Evac moved for summary judgment, arguing that the amended complaint was time-barred and did not relate back to the initial complaint. The trial court denied the motion.The Supreme Court of Alabama reviewed the case and determined that the amended complaint did not arise from the same conduct, transaction, or occurrence as the initial complaint. The amended complaint introduced entirely new facts and allegations, including actions by different individuals on a different day. Consequently, the amended complaint could not relate back to the initial complaint and was time-barred under the applicable statutes of limitations and repose. The Supreme Court of Alabama granted Air Evac's petition for a writ of mandamus, directing the trial court to vacate its order denying the summary judgment and to enter an order granting the motion. View "Ex parte Air Evac EMS, Inc." on Justia Law

Joyce Pates filed a medical malpractice lawsuit against Community Health Systems, Inc. (CHSI), Affinity Hospital, LLC, d/b/a Grandview Medical Center, Dr. John Kirchner, and Southlake Orthopaedics Sports Medicine and Spine Center, P.C. Pates alleged that after injuring her ankle and undergoing surgery performed by Dr. Kirchner at Grandview Medical Center, she experienced complications leading to an infection and ultimately the amputation of her right leg.The Jefferson Circuit Court denied the defendants' motions to dismiss, which argued that Pates's claims were barred by the two-year statute of limitations under the Alabama Medical Liability Act (AMLA). The court reasoned that Pates's injury began when she was informed of the need for amputation, thus starting the statute of limitations from that point.The Supreme Court of Alabama reviewed the case and determined that Pates's claims were indeed barred by the AMLA's statute of limitations. The court found that Pates's injuries, including signs of infection and the need for hardware removal, were evident by November 2020. Therefore, the statute of limitations began at that time, and Pates's complaint filed in February 2023 was outside the two-year limit. The court granted the petitions for writs of mandamus, directing the trial court to dismiss Pates's claims against the defendants. View "Ex parte Affinity Hospital, LLC" on Justia Law

John Cassimus, Jason T. Carrick, and Ryan McAllister were members of several limited-liability companies operating retail-liquidation stores, which have since closed. Carrick and McAllister alleged that Cassimus misused corporate assets for personal gain, while Cassimus claimed that Carrick and McAllister enriched their own company, Xcess Limited, at the expense of the stores. Carrick and McAllister sued Cassimus and his associates in the Shelby Circuit Court, asserting various claims including breach of fiduciary duty and fraud.The Shelby Circuit Court denied the Cassimus defendants' motion to dismiss the derivative claims, appointed a special master to oversee discovery, and dismissed claims against East Hampton Advisors, LLC, based on the abatement statute. The Cassimus defendants and Carrick and McAllister sought mandamus review of these orders in the Supreme Court of Alabama.The Supreme Court of Alabama reviewed the petitions. In case no. SC-2024-0284, the court denied the Cassimus defendants' petition, holding that the question of whether Carrick and McAllister could fairly and adequately represent the companies was a fact-intensive inquiry not suitable for mandamus review at the pleading stage. In case no. SC-2024-0318, the court dismissed the Cassimus defendants' petition as untimely because it was filed outside the presumptively reasonable time without a statement of good cause. In case no. SC-2024-0349, the court denied Carrick and McAllister's petition, holding that they had another adequate remedy through a Rule 54(b) appeal, which they did not pursue.The court lifted the stay previously entered and directed the trial court to resume proceedings. View "Ex parte Cassimus" on Justia Law

In 2020, Sarah E. Martin was injured in a car accident involving an 18-wheel tractor-trailer driven by Charles Streeter, an employee of Al-Amin Brothers Transportation, LLC. Martin sued the LLC, several individuals, and 18 fictitiously named defendants. In January 2023, Martin settled with the original defendants, agreeing to release them and related parties from any claims arising from the accident. Subsequently, Martin amended her complaint to add PEI Ohio, Inc. and Premium Transportation Group, Inc. (the corporations) as defendants, alleging various negligence and breach of contract claims.The Jefferson Circuit Court enforced the settlement agreement in favor of the corporations, dismissed Martin's third amended complaint, and awarded attorney fees to the corporations. Martin filed a fourth amended complaint, which remains pending. The circuit court certified its orders as final under Rule 54(b), Ala. R. Civ. P., and Martin appealed both the enforcement of the settlement and the attorney fee award.The Supreme Court of Alabama reviewed the case and determined that the circuit court exceeded its discretion in certifying the orders as final under Rule 54(b). The court found that the adjudicated and unadjudicated claims were closely related, the need for review might be mooted by future developments in the circuit court, and there was a possibility of having to consider the same issue again, particularly regarding attorney fees. Consequently, the Supreme Court of Alabama dismissed Martin's appeals, emphasizing the preference to avoid piecemeal litigation and the need for a final judgment on all pending claims before appellate review. View "Martin v. PEI Ohio, Inc." on Justia Law

Irva E. Reed sought to run for a seat on the Montgomery County Commission in 2024. She submitted her qualifying papers to the Montgomery County Democratic Party in November 2023 and confirmed she would submit a "Statement of Economic Interests" (SEI) to the Alabama Ethics Commission within five days, as required by Alabama law. However, she filed her SEI 41 days late. The Director of the Commission informed the Party that Reed was not qualified to appear on the ballot. Reed requested a five-day extension due to illness, but the Commission denied her request.Reed then sued the Director, the Chairman of the Commission, and the Secretary of State in their official capacities in the Montgomery Circuit Court, seeking a judgment declaring her illness as a valid reason for the delay and an injunction to place her name on the ballot. The trial court granted her request for a preliminary injunction, ordering the Commission and the Party to certify Reed as a candidate. The defendants appealed the trial court's order, and the Supreme Court of Alabama stayed the injunction while addressing the appeal.The Supreme Court of Alabama reviewed the case de novo and found that Reed's claim was moot because the election had already occurred. The court held that a judgment in Reed's favor would not affect the rights of the parties. The court also determined that none of the exceptions to mootness cited by Reed—capable of repetition but evading review, public interest, and collateral rights—applied in this case. Consequently, the Supreme Court of Alabama dismissed the appeal and instructed the trial court to dissolve the injunction and dismiss Reed's complaint. View "Plunk v. Reed" on Justia Law

Betty Callens, an 81-year-old woman, underwent left-hip-replacement surgery on September 23, 2019, at Grandview Medical Center. After her discharge on September 27, 2019, she was transferred to Brookdale Skilled Nursing Facility for rehabilitation. Callens alleged that she received poor nursing care at Brookdale, leading to a fall on October 3, 2019, which resulted in another fracture of her left hip and a fractured left femur. She was readmitted to Grandview for further surgeries and was later diagnosed with Clostridioides difficile. On October 15, 2019, Callens was transferred to St. Martin's for rehabilitation. On October 21, 2019, while being bathed by a nurse at St. Martin's, Callens alleged that the nurse applied excessive pressure to her healing hip, causing another dislocation.The Jefferson Circuit Court granted summary judgment in favor of St. Martin's, concluding that Callens failed to provide medical-expert testimony to establish a breach of the standard of care or causation of her injuries. Callens's motion to strike the affidavit of St. Martin's expert, Michael Britton, R.N., was denied. The court found that Britton was qualified as a similarly situated health-care provider.The Supreme Court of Alabama reviewed the case and affirmed the lower court's decision. The court held that Callens's case did not fall under the "layman" exception, which allows for the absence of expert testimony in cases where the lack of skill is apparent to a layperson. The court determined that the care provided to Callens involved complex medical procedures beyond the understanding of an average layperson, thus requiring expert testimony. The court also upheld the qualification of Britton as a similarly situated health-care provider, noting that he had provided hands-on care in the relevant field during the year preceding Callens's injuries. Consequently, the summary judgment in favor of St. Martin's was affirmed. View "Callens v. Episcopal Foundation of Jefferson County" on Justia Law

Carl Grant, a Vietnam War veteran suffering from dementia and PTSD, left his home in Conyers, Georgia, on February 2, 2020, and ended up in Birmingham, Alabama. Officer Vincent Larry of the Birmingham Police Department found Grant disoriented and detained him for a misdemeanor. Grant was taken to a hospital, where he was treated for minor injuries. While being escorted to the restroom, Larry allegedly assaulted Grant, causing severe spinal injuries that led to Grant's death on July 24, 2020. William Jenkins, representing Grant's estate, filed a lawsuit against Larry, the City of Birmingham, and various city officials.The Jefferson Circuit Court granted a summary judgment in favor of the City defendants, dismissing Jenkins's claims with prejudice on February 22, 2023. Jenkins filed a postjudgment motion on March 21, 2023, which was denied by operation of law on June 20, 2023. Jenkins also filed a "motion for clarification" on April 28, 2023, which the court purported to grant on June 21, 2023, reinstating claims against Larry and Scott Thurmond. However, this order was a nullity as the court had lost jurisdiction after the postjudgment motion was denied by operation of law.Jenkins filed a notice of appeal on November 3, 2023, which was dismissed as arising from a non-final order. He then filed another appeal on January 24, 2024, which was transferred to the Supreme Court of Alabama. The Supreme Court of Alabama dismissed the appeal, instructing the circuit court to vacate its June 21, 2023, order and all subsequent orders, as they were nullities. The February 22, 2023, judgment was deemed final, and Jenkins's failure to appeal it timely resulted in the dismissal of his current appeal. View "Jenkins v. City of Birmingham" on Justia Law

In May 2022, Jerry & John Woods Construction, Inc. ("Woods Construction") entered into a contract with John David Jordan and Carol S. Jordan to construct a house and a metal building. Woods Construction claimed the Jordans failed to pay for the work performed, leading the company to sue them in the Dallas Circuit Court for breach of contract and unjust enrichment. The Jordans moved to dismiss or for summary judgment, arguing that Woods Construction's lack of a required residential-home-builder's license barred the company from bringing civil claims. They also filed counterclaims alleging improper and negligent work by Woods Construction.The Dallas Circuit Court denied the Jordans' motion to dismiss but later granted their motion for summary judgment, finding that Woods Construction, as an unlicensed residential home builder, was barred from enforcing the construction contract under § 34-14A-14(d) of the Alabama Code. The court also declared Woods Construction's "Notice of Lis Pendens/Lien" null and void. The court certified its judgment as final under Rule 54(b), despite the Jordans' counterclaims remaining pending.The Supreme Court of Alabama reviewed the case and determined that the Rule 54(b) certification was improper. The court noted that the claims and counterclaims were closely intertwined, as both concerned the same contract and construction work. Additionally, the resolution of the Jordans' counterclaims could potentially moot Woods Construction's claims. Therefore, the court concluded that the circuit court exceeded its discretion in certifying the judgment as final and dismissed the appeal for lack of a final judgment. View "Jerry & John Woods Construction, Inc. v. Jordan" on Justia Law

Gary Everett Martin obtained a home-equity line of credit (HELOC) from BBVA USA Bancshares, Inc. (BBVA) in May 2008, secured by a mortgage on his residential property. In June 2008, Martin hired Joseph T. Scarborough, Jr., and Scarborough & Griggs, LLC (S&G) for legal representation in a divorce action. In June 2012, Martin executed a promissory note in favor of S&G for legal fees, secured by a second mortgage on the property. The attorney-client relationship ended in June 2013, and the promissory note and mortgage were later assigned to Scarborough. In June 2019, BBVA foreclosed on the property, and Scarborough purchased it at the foreclosure sale.The Lee Circuit Court granted summary judgment in favor of Scarborough, S&G, and BBVA, dismissing Martin's counterclaims and awarding possession of the property to Scarborough. The court found Martin's claims against the Scarborough parties time-barred under the Alabama Legal Services Liability Act (ALSLA) and dismissed his claims against BBVA as time-barred or unsupported by substantial evidence.The Supreme Court of Alabama reviewed the case. It found a genuine issue of material fact regarding the validity of the foreclosure sale, as the sale price was significantly lower than the property's fair market value, potentially indicating fraud or unfairness. Consequently, the court reversed the summary judgment in favor of Scarborough on his ejectment claim and remanded the case for further proceedings. However, the court affirmed the summary judgment in favor of the Scarborough parties and BBVA regarding Martin's counterclaims, finding them time-barred or unsupported by substantial evidence. View "Martin v. Scarborough" on Justia Law