Justia Alabama Supreme Court Opinion Summaries

In a dispute involving the foreclosure of a home, the Supreme Court of Alabama upheld the decisions of the lower court in favor of the purchasers of the foreclosed property and the mortgagee. The original homeowners, the Littlefields, defaulted on their mortgage payments and the property was subsequently foreclosed on by Planet Home Lending, LLC ("Planet"), and then sold to Terry Daniel Smith and Staci Herring Smith. The Littlefields refused to vacate the property, leading the Smiths to initiate an ejectment action against them. The Littlefields responded with counterclaims against the Smiths and Planet, arguing that the foreclosure was void because Planet had failed to comply with the mortgage's notice requirements. The Supreme Court of Alabama rejected the Littlefields' arguments, holding that any alleged noncompliance with the notice requirements would have rendered the foreclosure voidable, not void. The court concluded that because the Littlefields did not challenge the foreclosure before the property was sold to the Smiths, who were considered bona fide purchasers, the foreclosure could not be set aside. The court also noted that the Littlefields failed to challenge other rulings related to their counterclaims against Planet and their forfeiture of redemption rights, leading to these aspects of the lower court's judgment being affirmed as well. View "Littlefield v. Smith" on Justia Law

The Supreme Court of Alabama has reversed an order by the Dale Circuit Court, which held Omni Healthcare Financial, LLC in contempt for failing to comply with a subpoena. This case arose from claims asserted by Amy Lee Walker against Eric Irvin Reese and SCP Distributors, LLC, following an automobile collision. Omni, a North Carolina-based factoring company, had purchased certain accounts receivable from a medical provider who had treated Walker. The accounts receivable are secured by an interest in any recovery that Walker obtains from her lawsuit against the defendants. The defendants had served a nonparty subpoena on Omni's registered agent in Alabama, seeking certain documents. Omni later responded with some documents but also asserted objections to the subpoena. The defendants then filed a motion asking the circuit court to hold Omni in contempt of court for failing to comply with the subpoena. The circuit court granted this motion, leading to Omni's appeal. The Supreme Court of Alabama found that the trial court erred by holding Omni in contempt, as the subpoena was invalid. It was determined that the subpoena seeking documents located in North Carolina needed to be issued by a North Carolina court and served in accordance with North Carolina law. As the defendants had not asked a North Carolina court to direct Omni to produce the documents, they had not complied with the requirements to hold Omni in contempt. The case was reversed and remanded for further proceedings. View "In re Omni Healthcare Financial, LLC" on Justia Law

In Alabama, an attorney was representing three individuals, Charles, John, and Linda Evans, in relation to a car accident. Following the accident, Charles was taken to Shelby Baptist Medical Center and discharged. He subsequently collapsed at home and died. The attorney filed a complaint asserting medical malpractice, negligence, wantonness, and recklessness on behalf of John as next friend of Charles. Eventually, an insurance company provided a settlement check and a general release relating to Charles. However, this check was signed by John and not Charles' personal representative, Bowers, who had been appointed after Charles' death. The trial court ruled that the settlement was binding on Bowers, and all claims against the defendants were dismissed.Bowers appealed, and the Supreme Court of Alabama partially reversed the trial court's decision. It ruled that the trial court erred in entering a summary judgment in favor of the malpractice defendants without a motion from them and without holding an evidentiary hearing to determine whether the attorney had express or apparent authority to settle the wrongful-death claim against Short. The court affirmed the summary judgment in favor of Short with respect to John's and Linda's individual claims. The case was remanded to the trial court for further proceedings. View "Bowers v. BBH SBMC, LLC" on Justia Law

The circuit court entered a judgment on a jury verdict in favor of plaintiff Wayne Fagerstrom, individually and as the administrator of the estate of Sylvia Fagerstrom, deceased. The defendants were Mobile Infirmary Association d/b/a Mobile Infirmary Medical Center ("MIMC") and Gulf Health Hospitals, Inc., d/b/a Thomas Hospital. Defendants argued on appeal that the trial court erred in denying their renewed motion for a judgment as a matter of law at the close of all the evidence, in which they asserted that plaintiff failed to offer sufficient evidence demonstrating that the proximate cause of Sylvia's death was sepsis resulting from an infected pressure ulcer allegedly caused by the defendants' breaches of the standard of care. After review, the Alabama Supreme Court agreed with defendants and reversed the trial court's judgment. View "Mobile Infirmary Association v. Fagerstrom" on Justia Law

Plaintiff Octavi Perez appealed the grant of summary judgment in favor of Roman’s Restaurant, LLC, d/b/a Roman’s Night Club, on claims for damages under Alabama’s Dram Shop Act. In July 2019, 18-year-old Edgar Perez had been a patron of the nightclub and was killed when the vehicle he was driving left the roadway and hit a tree. An autopsy indicated Edgar was intoxicated at the time of his death. Plaintiff filed suit against Roman’s alleging it served alcoholic beverages to a minor, and Edgar’s subsequent intoxication precipitated Edgar’s death. Roman’s moved for summary judgment, arguing in relevant part that: (1) Plainitff lacked standing to sue on Edgar’s behalf because Plaintiff was neither Edgar’s parent nor stood in loco parentis; and (2) Plaintiff could not maintain an action under the Dram Shop Act because plaintiff had not been “injured in person, property or means of support.” The court record reflected Plaintiff was Edgar’s uncle, and Edgar contributed to the household expenses in the apartment he shared with Plaintiff and his father, Rigoberto Perez. The Alabama Supreme Court concluded the trial court did not err in entering summary judgment in Roman’s favor and affirmed. View "Perez v. Roman's Restaurant, L.L.C." on Justia Law

McMurray Contracting, LLC ("McMurray"), appealed a circuit court's denial of its second motion to compel arbitration of this case commenced by Kenneth Hardy and his wife Helen Hardy. The Hardys filed suit in December 2022 alleging they "retained" McMurray to perform restoration work to their house damaged in Hurricane Sally. The Hardys specifically alleged that McMurray "did not complete all restoration work in a good and workmanlike manner, and has refused to correct numerous deficiencies through [the Hardys'] property," and that McMurray "performed work and charged for materials that were never approved." The Alabama Supreme Court found McMurray's notice of appeal was not timely filed so as to invoke the Supreme Court's jurisdiction. Accordingly, it dismissed McMurray's appeal. View "McMurray Contracting, LLC v. Hardy" on Justia Law

Southern Lift Trucks, LLC ("Southern"), was an Alabama-based, heavy-equipment dealer for Hyundai Construction Equipment Americas, Inc. ("Hyundai Construction"). In May 2022, it filed suit against Hyundai Construction and its alleged parent company, Hyundai Heavy Industries Co., Ltd. (collectively, "Hyundai") asserting various claims. It also sought a preliminary injunction to prevent Hyundai from, among other things, unlawfully allowing Hyundai's dealers to sell certain equipment in Southern's designated territories or advertising that other dealers are authorized to sell that equipment in Southern's territories. Following a hearing, the circuit court entered an order granting Southern's request for a preliminary injunction. After the circuit court issued its injunction order, Southern learned that another Hyundai dealer had allegedly sold some equipment in one of Southern's territories. As a result, Southern filed a petition seeking a finding of contempt and sanctions against Hyundai. Following a hearing, the circuit court entered an order granting Southern's contempt petition. Hyundai appealed that contempt order on due process grounds. Because Hyundai was not given adequate notice of all the contempt allegations asserted against it before the hearing on those allegations (as required by Rule 70A, Ala. R. Civ. P.), the Alabama Supreme Court reversed the contempt order and remanded the case for further proceedings. View "Hyundai Construction Equipment Americas, Inc.v. Southern Lift Trucks, LLC" on Justia Law

The issue this case presented for the Alabama Supreme Court's review centered on the redemption of residential real property sold at a tax sale, specifically, the definition of the term "preservation improvements" as used in the applicable redemption statute, § 40-10-122, Ala. Code 1975. The property at issue had served as a rental home in a residential neighborhood. The property owner, J.C. King III, stopped paying property taxes in 2015 after a fire extensively damaged the property and rendered it uninhabitable. The State of Alabama purchased the property at a 2016 tax sale, and in 2019 the property was ultimately sold in its uninhabitable state to Anderson Realty Group, LLC ("ARG"). ARG spent $88,812 to extensively renovate and restore the property to a habitable condition, and in 2020 it filed a complaint seeking to quiet title to the property. King counterclaimed to redeem the property and disputed whether the extensive renovations to the property could be considered "preservation improvements" due to be included in the redemption amount pursuant to § 40-10-122(c). The trial court agreed with King, holding that "preservation improvements" included only those amounts expended by ARG to keep the property from further deterioration, the value of which it concluded was $10,000, and it entered a judgment setting the redemption amount accordingly. ARG appealed, and the Court of Civil Appeals reversed that judgment, holding that the trial court had erred in limiting the "preservation improvements" to the cost of repairs undertaken to keep the property in the same condition it was in at the time of the tax sale. To this, the Alabama Supreme Court concurred and affirmed the Court of Civil Appeals. View "Ex parte J.C. King III" on Justia Law

Andrew Spraggins's driveway crossed a neighboring tract of land owned by Ammons Properties, LLC ("Ammons"). After a dispute arose between Spraggins and Ammons, Spraggins filed a complaint asking a circuit court to declare he had an easement for the portion of his driveway that crossed Ammons' property. Ammons filed a counterclaim alleging that Spraggins was liable for several tortious acts. Following a bench trial, the circuit court ruled that Spraggins had an easement across Ammons' property and denied Ammons' counterclaims. Ammons appealed. Finding no reversible error, the Alabama Supreme Court affirmed the judgment. View "Ammons Properties, LLC v. Spraggins" on Justia Law

The Ohio Valley Conference ("the OVC" -- a collegiate athletic conference) appealed a judgment dismissing its official-capacity and individual-capacity claims against Randall Jones, the Chair of the Board of Trustees of Jacksonville State University ("JSU"), and Don C. Killingsworth, Jr., the President of Jacksonville State University. On February 3, 2021, JSU informed the OVC that it intended to resign its OVC membership effective June 30, 2021. OVC filed this action against JSU, Jones, and Killingsworth, seeking a declaratory judgment and alleging breach of contract -- focusing solely on JSU's failure to pay the conference-resignation fee described in Article 4.5.3 of the OVC Constitution. The complaint also asserted one count against JSU -- conversion -- focusing solely on the OVC's allegation that JSU had failed to pay $15,000 for tickets received from the OVC for the OVC's 2021 conference championship basketball tournament. The complaint also asserted two counts against JSU -- promissory estoppel and unjust enrichment -- that incorporated both the conference-resignation fee and the value of the tickets to the conference championship basketball tournament as elements of damages. The Alabama Supreme Court concluded: the OVC's claims against Jones and Killingsworth in their official capacities seeking payment for the liquidated amount of the conference-resignation fee and for the value of the tickets JSU received for the OVC's 2021 conference championship basketball tournament did not constitute claims against the State, and, therefore, they were not barred by State immunity. Accordingly, the circuit court erred in dismissing the OVC's official-capacity claims against Jones and Killingsworth. However, the Court found the OVC failed to state individual-capacity claims against Jones and Killingsworth for which relief could be granted because Jones and Killingsworth lacked any duty apart from their official positions to make the payments the OVC sought to recover and because the OVC's complaint did not supply the factual allegations necessary to support those individual-capacity claims. View "Ohio Valley Conference v. Jones, et al." on Justia Law