Justia Alabama Supreme Court Opinion Summaries

Jessica Eastman, as the dependent widow of David Bentley, and on behalf of Bentley's three minor children, appealed a judgment entered in favor of R. Warehousing and Port Services Inc. On appeal to the Supreme Court, she argued: (1) that she was entitled to a judgment as a matter of law on R. Warehousing's affirmative defense based on the "loaned-servant" doctrine; and (2) she was entitled to a new trial because counsel for R. Warehousing implied during opening statements that she had recovered workers' compensation benefits from Richway Transportation Services,Inc. in violation of the collateral-source rule. Finding no error, the Supreme Court affirmed. View "Eastman v. R Warehousing & Port Services, Inc. " on Justia Law

South Alabama Gas District (SAG) appealed a circuit court order enjoining it from selling liquified petroleum ("LP") gas and related appliances outside its member cities. Four individual taxpayers and Fletcher Smith Butane Co., Inc., sued SAG seeking both an injunction and damages for SAG's alleged violation of 11-50-266, as made applicable to gas districts by 11-50-399. The trial court bifurcated the claim for injunctive relief and the damages claim, and held a bench trial on the claim for injunctive relief. SAG argued that the notice and buy-out provisions did not apply to it because LP gas is not a "manufactured gas" within the terms of the statute. The trial court found otherwise and enjoined SAG from selling LP gas if it did not comply with 11-50-266. The circuit court found that the taxpayers lacked standing to challenge SAG's appliance sales. With regard to Fletcher Smith, SAG argued (among other things), that Fletcher Smith lacked standing because it sold its assets and was no longer engaging in the LP gas business. As proof, SAG cited Fletcher Smith's to "Requests for Admissions of Fact." After review of the circuit court record and the admissions cited by SAG in its appeal brief, the Supreme Court found that Fletcher Smith's claims for prospective relief became moot. "Because mootness goes to justiciability, this Court will not consider the merits of a claim that is moot." View "South Alabama Gas District v. Knight" on Justia Law

Defendant Reginald Tyrone Lightfoot challenged his conviction for trafficking in cocaine and his sentence of 15 years' imprisonment. The Supreme Court granted certiorari review to determine, as a matter of first impression, whether an Apprendi error in applying a sentence enhancement was automatically harmless when the erroneous application of the enhancement did not increase the sentence beyond the statutory maximum for the underlying offense. The Court held that it was not, and reversed the Court of Criminal Appeals. View "Lightfoot v. Alabama " on Justia Law

The Supreme Court held that Defendant's Rule 32 petition should not have been dismissed on the grounds that his claim for relief under Rule 32.1 lacked allegations to negate the preclusive bars of Rule 32.1(a)(3) and (5). Defendant was convicted of capital murder and sentenced to death. He filed a Rule 32 petition for post-conviction relief, alleging in part that the State failed to disclose exculpatory evidence. The State asserted in response that defendant's claims were procedurally barred by Rule 32.2(a)(3) and (5) because defendant could have, but did not, raise the issue at trial. The trial court dismissed defendant's application and the Court of Criminal Appeals affirmed. The case was remanded for further proceedings. View "Beckworth v. Alabama" on Justia Law

Luther Pate, IV sought review of the Court of Criminal Appeals' decision to affirm his conviction for menacing. In a matter of first impression, the issues before the Supreme Court were: (1) whether lawfully arming oneself was a "physical action" as defined in the state menacing statute; and (2) whether defense-of-premises was applicable in this case. Finding that the Court of Criminal Appeals erred in its analysis of the menacing statute, the Supreme Court reversed and remanded the case for further proceedings. The Court held that its reversal on the menacing issue pretermitted discussion of the defense-of-premises issue. View "Pate IV v. City of Tuscaloosa" on Justia Law

Defendants U.S. Innovations Group, Inc. (and several others) petitioned the Supreme Court for a writ of mandamus to order the trial court to dismiss claims filed against it by Judy Hawke and Carolyn Grimes. Defendants argued that because the claims arose on a federal enclave subject to exclusive federal jurisdiction, the trial court lacked jurisdiction to hear the claims. Finding that defendant did not demonstrate the trial court lacked jurisdiction or that they had a clear right to have those claims dismissed, the Supreme Court denied their petitions for the writ. View "Hawke v. U.S. Centrifuge Systems, LLC" on Justia Law

USA Water Ski, Inc. sought a writ of mandamus to direct the trial court to vacate its discovery order compelling the production of a report that it deemed privileged under the work-product doctrine. Finding that USA Water Ski adequately explained that it's hired expert's post-incident report was prepared because of prospective litigation, the Supreme Court found USA Water Ski had shown the trial court exceeded its discretion in ordering production of the report. Accordingly the Court granted the petition and issued the writ. View "Ewing v. USA Water Ski, Inc." on Justia Law

Petitioner Tonya Cate sought a writ of mandamus to direct the trial court to vacate its order requiring her to submit for a mental examination. She was indicted for capital murder and did not use the not-guilty-by-reason-of-mental-defect defense. At the onset, a mitigation expert was concerned Petitioner had not been subjected to the exam to determine her competency to stand trial. Petitioner's attorney filed a motion for a continuance for his client to be examined, but did not specify that the exam was only to determine competence. The State filed a motion to have Petitioner examined for both current mental condition and competency to stand trial. Petitioner claims to have not been served with a copy of the trial court's order that granted the State's motion, and objected. In her motion to avoid the exam, Petitioner asked in the alternative that if the exam took place, her attorney be present to advise her of her constitutional rights. Before the court ruled on the motion, Petitioner withdrew her original motion, citing the mitigation expert's concerns had been allayed. The court entered its order requiring Petitioner to submit to the examination for then-current mental state and at the time of the alleged crime. Petitioner argued that after withdrawing her own motion for an examination, she could not be compelled to submit for examination. Because Petitioner did not use the mental-defect defense, the Supreme Court concluded that she could not be compelled to submit to the examination. Accordingly the Court granted the petition and issued the writ. View "Cate v. Alabama " on Justia Law

Plaintiff SafetyNet Youth Systems, LLC sued Defendants Guarantee Insurance Company, Patriot National Insurance Group, Randy Thomas, and Paul Harper in Dallas County Circuit Court. Defendants sought the writ of mandamus to direct the Dallas court to grant their motion for a transfer of venue to Lee County. Upon review, the Supreme Court concluded Dallas County was an inappropriate forum, and granted defendant's petition and issued the writ. View "Safetynet Youth Systems, LLC v. Guarantee Insurance Co." on Justia Law

Tyson Foods, Inc. petitioned the Supreme Court for a writ of mandamus to direct the Blount Circuit Court to dismiss Reba Kirkley's action against it, brought in her capacity as administratrix of her father's estate, on the ground that Kirkley lacked standing. On April 15, 2008, Allen Hayes died in a workplace accident at the Tyson Foods plant in Blount County. A tractor operated by an employee of Tyson Foods hit Hayes, who was working as a security guard. His widow Mildred Hayes collected $40,964.19 in workers' compensation death benefits against the account of DSI Security Services, Allen's employer at the time of the accident. On June 26, 2008, Kirkley, the personal representative of Allen's estate and Allen and Mildred's daughter, filed a wrongful-death action against the Tyson petitioners, who answered and removed the case to federal court. In early March 2011, the federal court remanded the case to state court. The trial judge denied the motion to dismiss. Finding that Tyson did not demonstrate a clear legal right to the remedy it sought seek, the Supreme Court denied the petition. View "Kirkley v. Tyson Foods, Inc." on Justia Law