Justia Alabama Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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In response to economic conditions related to the spread of COVID-19, Congress established several programs that made additional federal funds available to the states for providing enhanced unemployment-compensation benefits to eligible individuals. Alabama elected to participate in the programs, and Shentel Hawkins, Ashlee Lindsey, Jimmie George, and Christina Fox, were among the Alabamians who received the enhanced benefits. As the spread of COVID-19 waned, Governor Kay Ivey announced that Alabama would be ending its participation in the programs. When Alabama did so, the claimants received reduced unemployment-compensation benefits or, depending on their particular circumstances, no benefits at all. Two months later, the claimants sued Governor Ivey and Secretary of the Alabama Department of Labor Fitzgerald Washington in their official capacities, alleging that Alabama law did not permit them to opt Alabama out of the programs. After a circuit court dismissed the claimants' lawsuit based on the doctrine of State immunity, the claimants appealed. Finding no reversible error, the Alabama Supreme Court affirmed the circuit court. View "Hawkins, et al. v. Ivey, et al." on Justia Law

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These consolidated appellate proceedings arose from a quo warranto action filed by the State of Alabama, on the relation of Charles Driggars, challenging Governor Kay Ivey's appointment of James Naftel II to the office of Judge of Probate of Jefferson County, place no. 1. In case no. 1200755, Judge Naftel, individually and in his official capacity, and Governor Ivey appealed a circuit court order denying their motion for a summary judgment. After review, a majority of the Alabama Supreme Court reversed that order and the case remanded for the circuit court to enter summary judgment in Judge Naftel and the Governor's favor. The Court's resolution of the appeal in favor of Judge Naftel and Governor Ivey made the relief sought in their petition for a writ of mandamus moot; the petition was therefore dismissed. View "Naftel v. Alabama ex rel. Driggars" on Justia Law

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Richard Glass appealed a circuit court judgment upholding the constitutionality of a municipal ordinance and a corresponding local act that authorized automated photographic enforcement of traffic-light violations within the corporate limits of the City of Montgomery ("the City"). Glass claimed the ordinance and the local act violate dArt. VI, sections 89, 104, and 105, Ala. Const. 1901 (Off. Recomp.). On August 7, 2017, Glass ran a red light at an intersection within the corporate limits of the City. The automated camera equipment at the intersection detected and photographed Glass's vehicle running the red light. As a result, the City issued Glass a civil citation. At the hearing, Glass did not dispute that his vehicle was photographed running the red light. Instead, Glass challenged the constitutionality of the Ordinance and the Act. The municipal court concluded that it lacked jurisdiction to decide Glass's constitutional claims, and it found Glass liable for the red-light violation. After review, the Alabama Supreme Court concluded Glass did not demonstrate the Ordinance and Act violated sections 89, 104, or 105 of the Alabama Constitution. Accordingly, the Court affirmed the trial court's judgment upholding the constitutionality of both. View "Glass v. City of Montgomery" on Justia Law

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In 2018, pursuant to a premises search warrant, police in Mobile, Alabama searched the residence of Joshua Moyers, seeking evidence of drug activity. Although Moyers was referenced in the affidavit supporting the issuance of the warrant, no individuals were named in the warrant itself. Police entered Moyers's house and discovered Nancy Powers sleeping on a couch in the first room of the house. Powers's purse was sitting on a table next to the couch. After confirming with Powers that the purse belonged to her, police searched the purse and discovered methamphetamine, a digital scale, and cash. Relevant to these proceedings, Powers was charged with possession of methamphetamine with intent to distribute. The circuit court denied Powers's motion to suppress the evidence found in her purse. Thereafter, Powers pleaded guilty and appealed to the Court of Criminal Appeals, challenging the trial court's denial of the motion to suppress. The Court of Criminal Appeals unanimously affirmed the trial court's ruling. The Alabama Supreme Court granted Powers's petition for a writ of certiorari to consider a question of first impression: whether police improperly searched Powers' purse, or whether, as the State argued, the purse was simply a container in the House that fit within the scope of the premises warrant. The Supreme Court agreed with the State that the purse was a container that came within the scope of the warrant, and that Powers' right to privacy was not violated. View "Ex parte Nancy Powers." on Justia Law

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The Alabama Space Science Exhibit Commission d/b/a U.S. Space & Rocket Center ("ASSEC") filed suit against Space Race, LLC ("Space Race"), seeking to avoid an arbitration award entered in favor of Space Race and against ASSEC by an arbitration panel in New York. In July 2016, Space Race agreed to produce an animated series for ASSEC aimed at promoting the interest of children in space exploration and science. The series was to be created and released to the public over a three-year period. In exchange, ASSEC agreed to compensate Space Race with funds ASSEC would receive from a grant from the National Aeronautics and Space Administration ("NASA"), which had contracted with ASSEC to provide funding for the series. The compensation was to be paid to Space Race annually as the series episodes were created during the three-year contract term. The parties' agreement provided that it "shall be governed" by Alabama law. Space Race produced the series before the contract term expired, but ASSEC failed to pay the amount owed for the last year of the series. Space Race claimed that ASSEC still owed Space Race approximately $1.3 million when the contract term expired. The parties' agreement contained an arbitration provision. In December 2017, after being notified by ASSEC that it would no longer make payments to Space Race because the grant from NASA had been terminated, Space Race commenced arbitration proceedings against ASSEC in New York. Space Race moved to dismiss ASSEC's Alabama action, asserting that a New York court had already entered a final judgment confirming the arbitration award. The Alabama trial court denied Space Race's motion to dismiss, and Space Race petitioned the Alabama Supreme Court for a writ of mandamus directing the trial court to dismiss ASSEC's action. Because the New York judgment confirming the arbitration award against ASSEC was entitled to full faith and credit and res judicata effect, the Supreme Court granted Space Race's mandamus petition. The trial court was directed to vacate its order denying Space Race's motion to dismiss and to enter an order granting that motion. View "Ex parte Space Race, LLC." on Justia Law

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David Bronner, secretary-treasurer of the Public Education Employees' Health Insurance Plan ("PEEHIP"), and individual members of the Board of Control of PEEHIP ("the PEEHIP Board"), the remaining defendants in this action (collectively, "defendants"), appealed the grant of summary judgment entered in favor of the plaintiffs and members of a purported class, who were all active public-education employees and PEEHIP participants married to other active public-education employees and PEEHIP participants and who had dependent children. Before October 1, 2010, all public-education employees participating in PEEHIP earned a monthly "allocation" or benefit, which could be used to obtain certain coverage alternatives under PEEHIP. In May 2010, the PEEHIP Board voted to eliminate "the combining allocation program" and to phase in a new premium rate structure ("the 2010 policy"), which required a public-education employee married to another public-education employee to gradually begin paying the same monthly premiums for family hospital-medical coverage that other PEEHIP participants were required to pay. In May 2014, the original named plaintiffs, individually and on behalf of a class of similarly situated individuals, filed a purported class action against the defendants, among others, pursuant to 42 U.S.C. 1983. In their complaint, the original named plaintiffs sought a judgment declaring that the 2010 policy was unconstitutional under the Due Process Clause and the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution because, they claimed, the 2010 policy denied them and the members of the purported class a benefit for the payment of insurance accorded every other PEEHIP participant. The original named plaintiffs sought an order enjoining the defendants from denying them and the members of the purported class the use of that benefit, which, they claimed, would permit them and the members of the purported class to obtain family coverage at no cost. The defendants thereafter moved for a summary judgment, which the trial court denied. The Alabama Supreme Court reversed, finding nothing to indicate that the defendants intended to single out the public-education plaintiffs for disparate treatment under the 2010 policy. Accordingly, the Court concluded the 2010 policy was neither arbitrary nor discriminatory and that it did not violate either the Equal Protection Clause or the Due Process Clause of the Fourteenth Amendment to the United States Constitution. View "Bronner, et al. v. Barlow et al." on Justia Law

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Sherman Collins petitioned the Alabama Supreme Court for certiorari review of the Court of Criminal Appeals' judgment affirming Collins's convictions for capital murder for the intentional killing of Detrick Bell for pecuniary gain, and for criminal conspiracy. The appellate court also affirmed his resulting sentences of death for his capital-murder conviction and of 120 months' imprisonment for his criminal-conspiracy conviction. The Supreme Court granted review to consider whether the Court of Criminal Appeals' decision was in conflict with Blockburger v. United States, 284 U.S. 299 (1932); the Alabama Court concluded that it was. As a result, the Supreme Court affirmed the Court of Criminal Appeals' decision insofar as it affirmed Collins's capital-murder conviction and his resulting death sentence, but reversed the decision insofar as it affirmed Collins's criminal-conspiracy conviction and his resulting sentence to 120 months' imprisonment. The case was remanded to the Court of Criminal Appeals to remand the cause to the trial court to set aside Collins's criminal-conspiracy conviction and resulting sentence. View "Ex parte Sherman Collins" on Justia Law

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Tom Young, Jr., a former circuit judge for the Fifth Judicial Circuit; Ray Martin, a circuit judge for the Fifth Judicial Circuit; Chris May, the Randolph Circuit Clerk; and Marlene Lindley, a former employee in May's office, petitioned the Alabama Supreme Court for a writ of mandamus directing the trial court to dismiss a complaint filed by Danny Foster, an inmate at the Ventress Correctional Facility, on grounds that they were immune from suit, that Foster lacked standing to sue, and that Foster's claims were precluded by the applicable statute of limitations. The Alabama Supreme Court found May and Lindley make no argument that, based on the face of Foster's complaint, they had a clear legal right to a summary judgment on the ground that the applicable statute of limitations barred Foster's claim against them. Moreover, Foster's complaint was devoid of any information from which the Supreme Court could determine that his claim against May and Lindley was untimely. He did not provide the dates on which he submitted his records requests. May and Lindley, therefore, "have not demonstrated that this case falls within the exception recognized in Hodge to the general rule against review by mandamus of the applicability of a statute-of-limitations defense." The Supreme Court granted the defendants' petition insofar as it sought a writ of mandamus directing the trial court to enter a summary judgment in favor of Judge Young and Judge Martin on grounds that all the claims asserted against them by Foster were barred by the doctrine of judicial immunity. The Court denied the petition, however, insofar as it sought a writ of mandamus instructing the trial court to enter a summary judgment in favor of May and Lindley regarding Foster's claim against them under the Open Records Act. View "Ex parte Young, Jr.; Martin; Lindley; and May." on Justia Law

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Johnny Lee Self petitioned the Alabama Supreme Court for review of a Court of Criminal Appeals' decision to affirm the summary dismissal of his petition for postconviction relief. In September 2003, Self pleaded guilty to two counts of first-degree sexual abuse, and was sentenced to 25 years' imprisonment; the crime of sexual abuse in the first degree was a Class C felony. Self did not appeal. In 2019, Self petitioned to challenge his convictions and sentences, arguing he had been improperly sentenced to serve 25 years in prison because the maximum sentence authorized for a Class C felony was 10 years, and, Self asserted, he "was not sentenced as a [h]abitual [o]ffender." Self also alleged "that nothing in the record shows that his sentence was properly enhanced." In 2020, the State responded, arguing Self's claim was not a jurisdictional claim, and was barred by the limitations period set forth in Rule 32.2(c), Ala. R. Crim. P. The circuit court summarily dismissed Self's Rule 32 petition, interpreting Self's claims in his Rule 32 petition as (1) a claim "that the State failed to adequately prove [Self's] prior felony convictions that were used to enhance his sentence" and (2) a claim "that the record does not reflect application of the Habitual Felony Offender Act." The Supreme Court granted certiorari review to consider whether the Court of Criminal Appeals' decision was in conflict with Barnes v. State, 708 So. 2d 217 (Ala. Crim. App. 1997), the facts of which were similar to those presented in this case. After review, the Supreme Court concluded the Court of Criminal Appeals' decision was in conflict with Barnes, thus reversing the Court of Criminal Appeals' judgment. View "Ex parte Johnny Lee Self" on Justia Law

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Amy Williamson petitioned the Alabama Supreme Court for a writ of mandamus directing the Tuscaloosa Circuit Court to enter a summary judgment in her favor based on State-agent immunity. Twenty-year-old Re.W. was a student in the CrossingPoints program, a collaborative program between the University of Alabama, the Tuscaloosa City Board of Education, and the Tuscaloosa County Board of Education that served college-aged students with mental disabilities. Williamson was a teacher in the program and an employee of the Tuscaloosa City Board of Education, and Amy Burnett was a "para-educator" with the program. In 2015, Williamson and Burnett transported Re.W. and three other students to various businesses to submit job applications. While Williamson and Burnett took two students into a Lowe's home-improvement store to submit applications, Re.W. and a male student stayed in the CrossingPoints van. Re.W. stated that, during the short time that the others were inside the store, the male student touched her on her breast and between her legs. In 2019, Re.W., by and through her parents and next friends, Ro.W. and V.W., sued Williamson on counts of negligent, wanton, and/or willful failure to perform ministerial acts and the tort of outrage. Williamson filed an answer to the complaint denying the material allegations and asserted multiple affirmative defenses. Williamson later moved for summary judgment, asserting, among other things, that Re.W.'s claims were barred by the doctrine of State-agent immunity. Because the Alabama Supreme Court concluded that Williamson established that, at the time of the incident, she was performing a discretionary function, and because the Court concluded Re.W. did not present any evidence to establish that an exception to State-agent immunity applied, Williamson established that she was entitled to State-agent immunity. Accordingly, the petition for the writ of mandamus was granted and the trial court directed to vacate its order denying Williamson's motion for a summary judgment, and directed to enter a summary judgment for Williamson. View "Ex parte Amy Williamson." on Justia Law