Justia Alabama Supreme Court Opinion SummariesArticles Posted in Constitutional Law
Burkes v. Franklin
This appeal arose from a quo warranto action initiated by a February 2022 complaint filed Frederick A. Burkes, Sr., on the relation of the State of Alabama, in which he alleged that James Franklin "has unlawfully usurped the public office of the constable for District 59 in Jefferson County, Alabama." Franklin moved to dismiss the quo warranto action in June 2022, which the circuit court granted. In July 2022, the Alabama Supreme Court issued its decision in a case related to this quo warranto action, holding the circuit court lacked subject-matter jurisdiction because Burkes had not given the circuit court security for costs, as required by § 6-6-591(b), Ala. Code 1975, and that the circuit court's judgment in the prior action was therefore void. This Court then dismissed the appeal because a void judgment will not support an appeal. Burkes argued here that, because the circuit court did not have subject-matter jurisdiction over the prior action, the circuit court erroneously dismissed the quo warranto action on the grounds of res judicata and collateral estoppel. To this the Supreme Court concurred, reversed dismissal of the quo warranto action, and remanded for further proceedings. View "Burkes v. Franklin" on Justia Law
Ex parte Charlie Byrd
After being indicted by a grand jury for unlawful possession of a controlled substance -- delta-9- tetrahydrocannabinol (synthetic marijuana), Charlie Byrd filed a motion to suppress the evidence that was the basis of his indictment on the ground that it was the product of an unlawful search and seizure. The motion was denied, and Byrd conditionally pled guilty, reserving the right to appeal the denial of the motion to suppress. Byrd was sentenced to 60 months in prison, with 12 served and 24 months of supervised probation. The Court of. Criminal Appeals affirmed Byrd’s conviction, and he appealed to the Alabama Supreme Court. Finding no reversible error, the Supreme Court affirmed the Court of Criminal Appeals. View "Ex parte Charlie Byrd" on Justia Law
Jones v. Alabama
In January 2018, Whitney Jones, an inmate in the Mobile County Metro Jail and a participant in the jail's work-release program, left her work-release job and did not return to the work-release barracks. As a result, Jones was charged with, and convicted of, second-degree escape, a felony. The Alabama Court of Criminal Appeals affirmed Jones's conviction. The Alabama Supreme Court granted certiorari review to consider whether an inmate, like Jones, who escapes from a county work-release program authorized pursuant to Ala. Code 1975, §§ 14-8-30 through 14-8-44 ("the county work-release statutes"), could be convicted of escape pursuant to one of the escape statutes in the Alabama Criminal Code, Ala. Code 1975, §§ 13A-10-30 through 13A-10-33 ("the escape statutes"), which would be punishable as a felony, or whether such an escape is punishable only as a misdemeanor pursuant to Ala. Code 1975, §§ 14-8-42 and 14-8-43. The Supreme Court concluded that escapes from county work-release programs were governed by the escape statutes. Accordingly, the Court affirmed the judgment of the Alabama Court of Criminal Appeals. View "Jones v. Alabama" on Justia Law
Ex parte Whitney Owens Jones.
In January 2018, Whitney Jones, an inmate in the Mobile County Metro Jail and a participant in the jail's work-release program, left her work-release job and did not return to the work-release barracks. As a result, Jones was charged with, and convicted of, second-degree felony escape. The Alabama Court of Criminal Appeals affirmed Jones's conviction. The Alabama Supreme Court granted certiorari review to consider whether an inmate, like Jones, who escapes from a county work-release program authorized pursuant to Ala. Code 1975, §§ 14-8-30 through 14-8-44 could be convicted of escape pursuant to one of the escape statutes in the Alabama Criminal Code, Ala. Code 1975, §§ 13A-10-30 through 13A-10-33 ("the escape statutes"), which would be punishable as a felony, or whether such an escape was punishable only as a misdemeanor pursuant to Ala. Code 1975, §§ 14-8-42 and 14-8-43. The Supreme Court concluded that escapes from county work-release programs were governed by the escape statutes. View "Ex parte Whitney Owens Jones." on Justia Law
Ex parte Hunter Halver Brown.
Hunter Halver Brown petitioned the Alabama Supreme Court for certiorari review in which a circuit court had denied Brown's motion to dismiss the indictment against him notwithstanding the State's purported failure to comply with the Uniform Mandatory Disposition of Detainers Act, 15-9-80 et seq., Ala. Code 1975 ("the Act"), a codification of the federal Interstate Agreement on Detainers, 18 U.S.C. App. 2 ("the IAD"). The Supreme Court granted certiorari review to consider whether, as a matter of first impression, its Court's statewide suspension of jury trials in response to the COVID-19 pandemic tolled the Act's 180-day time limit for bringing a prisoner to trial. The Court held that it did, and affirmed the Court of Criminal Appeals' decision to affirm the circuit court. View "Ex parte Hunter Halver Brown." on Justia Law
Hawkins, et al. v. Ivey, et al.
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
Naftel v. Alabama ex rel. Driggars
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
Glass v. City of Montgomery
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
Posted in: Constitutional Law
Ex parte Nancy Powers.
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
Ex parte Space Race, LLC.
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