Justia Alabama Supreme Court Opinion Summaries

The State of Alabama petitioned the Supreme Court for a writ of mandamus to direct the Court of Criminal Appeals to vacate its order that granted a mandamus petition filed by Jeremy B. Jones, and that directed Mobile Circuit Judge Charles Graddick to recuse himself from presiding over Jones's postconviction proceedings. In October 2005, Judge Graddick presided over a trial in which Jones was convicted on four counts of capital murder and was sentenced to death. The jury was sequestered throughout the trial, which lasted several days. After his conviction and sentence were affirmed on appeal, Jones filed a petition for postconviction relief. In that petition Jones alleged that juror "T.E." was unfit to serve on the jury on account of alcohol dependence and that T.E. had failed to answer truthfully certain questions on voir dire regarding his alcohol dependence. According to Jones, posttrial interviews revealed: (1) that T.E. had told Judge Graddick during Jones's trial that he was an alcoholic; (2) that T.E. had received permission from Judge Graddick to drink alcohol during sequestration; and (3) that Judge Graddick did not inform Jones's counsel that T.E. had requested such permission and that Judge Graddick had granted it. Jones's petition alleged juror misconduct, as well as juror incompetence. Upon review, the Supreme Court concluded that because Judge Graddick would not be a material witness in Jones's postconviction proceedings, no "reasonable person knowing everything that the judge knows would have a 'reasonable basis for questioning the judge's impartiality.'" Thus, the Court held Judge Graddick did not exceed his discretion in denying Jones's motion for his recusal, and the Court of Criminal Appeals erred in holding that he did. The Court granted the State's petition for mandamus. View "Alabama vs. Jones" on Justia Law

The University of South Alabama Medical Center and the University of South Alabama Children's and Women's Hospital appealed the grant of summary judgment in favor of Mobile County. The County filed a complaint seeking a judgment to interpret Act 83-501. In its complaint, the County asserted that the Act was indefinite and unclear as to which hospitals qualify for reimbursements and the amount of those reimbursements. The County named several hospitals as defendants, including the University of Southern Alabama Children's and Women's Hospital. The Hospitals answered the complaint asserting that the Act is not indefinite, and that Mobile County previously provided reimbursement for providing indigent care and that it could continue to do so "based on established procedures and precedence and the plain meaning of the Act." In its review, the Supreme Court concluded that there was no justiciable controversy; Mobile County only sought an advisory opinion in its declaratory-judgment complaint. The trial court therefore lacked subject-matter jurisdiction over this action. The Court vacated the trial court's order and dismissed the case. View "Univ. of So. Alabama Med. Ctr. v. Mobile Infirmary Association" on Justia Law

The issue before the Supreme Court pertained to the admissibility into evidence a child witness's prior inconsistent out-of-court statements. The Court granted certiorari to address this as an issue of first impression: whether a part of the Child Physical and Sexual Abuse Victim Protection Act conflicted with the Alabama Rules of Evidence. The Court of Criminal Appeals held that an "inherent tension" existed between the Act and the Rules of Evidence insofar as it permitted a prior inconsistent out-of-court statement of a child witness to be considered substantive evidence of asserted facts when the rules considered those statements as hearsay. "M.L.H." was adjudicated a youthful offender based on the trial court's finding that he was guilty of first-degree sodomy, and he was sentenced accordingly. M.L.H. appealed, and the Court of Criminal Appeals determined that M.L.H.'s prior out-of-court statements, although admissible as substantive evidence under the Act, were inadmissible as substantive evidence under the rules of evidence. The court reversed the trial court's judgment and remanded the case for a new trial. The State appealed. Upon review, the Supreme Court reversed the Court of Criminal Appeals, finding no conflict between the Act and the rules of evidence. The case was remanded for reassessment of the substantive admissibility of M.L.H.'s prior inconsistent out-of-court statements. View "M. L. H. v. Alabama" on Justia Law

Defendant Brandon Mitchell was convicted on four counts of capital murder for killing three people during the course of a robbery at a hotel. The jury recommended that Defendant be sentenced to life in prison without the possibility of parol on each conviction. After considering Defendant's presentence report and holding a sentencing hearing, the trial court overrode the jury's recommendation and sentenced Defendant to death. The Court of Criminal Appeals affirmed. Defendant petitioned the Supreme COurt for a writ of certiorari to review the decision of the appellate court, asserting seventeen separate grounds for review. The Court granted the writ in May 2011, and issued the writ to examine the sole question on whether the trial court complied with Ala. Code 1975 section 13A-5-47(d) and (e). Upon receiving the record, the Court determined the writ was "improvidently issued" and quashed it. The Court found that the trial court fully complied with Alabama Code. View "Mitchell v. Alabama " on Justia Law

Defendant James Beauford Lamb, Jr. appealed the Court of Criminal Appeals' affirmance of his 2004 conviction for first-degree sexual abuse. The issue on appeal was whether the trial court erred in entering a judgment based on an amended written jury verdict that differed from one taken from a direct poll of the jury after it had been discharged from its duty. Alabama case law held that once a jury had been discharged and "left the court's control, the jury could not properly be resummoned to correct or amend an insufficient verdict, and that the judgment entered on the amended verdict of that recalled jury must be reversed." Following precedent, the Supreme Court concluded that the amended verdict would constitute double jeopardy. Accordingly, the Court reversed the appellate court's affirmance of the amended verdict and remanded the case for further proceedings. View "Lamb v. Alabama" on Justia Law

Defendant T.D.M. was convicted on one count of first degree sexual abuse and one count of first degree sodomy. At the end of Defendant's trial, the jury first returned verdicts of guilty and not guilty, respectively. The jury was then discharged. The clerk of the court informed the trial judge that due to a clerical error, the 'not-guilty' verdict was entered incorrectly. The jury was recalled, and each juror polled stated that he/she had voted Defendant guilty on the sodomy charge. Ultimately the trial court entered a corrected judgment finding Defendant guilty on the sodomy charge, and passed sentence accordingly. Defendant unsuccessfully appealed the convictions. The issue before the Supreme Court was whether Defendant's constitutional rights against double jeopardy had been violated by the poll of the jury and change in Defendant's sentence. Upon review, the Supreme Court found that under the circumstances of this case, Defendant's constitutional rights were violated. The Court reversed the sodomy conviction and remanded the case for further proceedings. View "T. D. M. v. Alabama " on Justia Law

Defendants the Colbert County Board of Education ("the Board"); and the individual members of the Board and members of the Colbert County High School appealed a trial court's judgment that granted Plaintiff Felecia James's motion for a preliminary injunction. On or about May 21, 2010, an incident occurred at Colbert County High School (CCHS) involving J.H., Plaintiff's minor child, and another minor enrolled in CCHS. The details of the incident were disputed, but they led the assistant principal of the school to suspend both students for three days for allegedly fighting on school property during school hours. Plaintiff appeared before the Board to discuss the situation. The Board apparently took no action, and Plaintiff "individually and as mother and guardian of J.H." sued the Board and the individually named defendants asserting state-law and federal-law claims She also filed a motion for a temporary restraining order, a preliminary injunction, and a permanent injunction. Upon review, the Supreme Court found that the Board members in their official capacities were immune from the state-law claims filed against them insofar as those claims sought monetary damages. As such, the trial court lacked subject-matter jurisdiction over those state-law claims against the officials in their official capacities. However, the Board members were not immune from Plaintiff's state-law claims insofar as she sought injunctive relief based upon the Board members' alleged fraud, bad faith, or actions that were beyond the Board members' authority or that were taken under a mistaken interpretation of law. The Court noted that the Board and its members were not immune from the federal-law claims filed against them. Based on the foregoing, insofar as the Board appealed the preliminary injunction against it based upon the state-law claims filed by Plaintiff, the Supreme Court dismissed their appeal for lack of subject-matter jurisdiction. Because the Court reversed the preliminary injunction, the Court declined to order the trial court to vacate the preliminary injunction entered against the Board insofar as it was based on those claims. View "Colbert Cty. Bd. of Edu. v. James" on Justia Law

The State petitioned the Supreme Court for a writ of certiorari to review the Court of Criminal Appeals' decision to reverse Sean Travis Howard's criminal conviction based on the trial court's failure to charge the jury on manslaughter as a lesser offense to capital murder, the offense with which Howard was charged. The Court granted review to consider whether the Court of Criminal Appeals' decision conflicted with its decision in "Fox v. State." The Court concluded that it did, and reversed the Court of Criminal Appeals' judgment: "Reckless murder and reckless manslaughter do not involve the same degree of recklessness. … [t]he difference between the circumstances which will support a murder conviction and the degree of risk contemplated by the manslaughter statute is one of degree, not kind. ... [T]he degree of recklessness which will support a manslaughter conviction involves a circumstance which is a 'gross deviation from the standard of conduct that a law-abiding person would observe in the actor's situation,' but is not so high that it cannot be 'fairly distinguished from' the mental state required in intentional homicides." Accordingly, the Court reversed the Court of Criminal Appeals and remanded the case for further proceedings. View "Howard v. Alabama" on Justia Law

The United States District Court for the Northern District of Alabama, Southern Division sent a certified question to the Supreme Court. While the Court initially accepted the certified question; however upon review, the Court declined to answer it. The Court noted that the certified question was framed in the abstract, with no reference to any specific language in the title-insurance policy at the heart of the case (i.e., as an evidentiary issue with broad application). "The parties, in their briefs to this Court, do not address the construction of the policy at issue and instead refer this Court to various authorities discussing how valuation may be determined in various title-insurance contexts. Additionally, it is not apparent from the materials before us that the district court has had the opportunity to address whether the specific language of the policy would control the determination of the value of the property. Therefore, we see no grounds under Rule 18 [of the Rules of Alabama Civil Procedure] that will allow this Court to answer the question." View "Stewart Title Guaranty Company v. Shelby Realty Holdings, L.L.C." on Justia Law

Students and former students of the University of Alabama, Auburn University, and the University of Alabama at Birmingham, filed three separate class-action lawsuits in the Jefferson Circuit Court challenging the legality of so-called "dining-dollars" programs implemented by the universities and pursuant to which all undergraduate students were required to pay a mandatory dining fee each semester, which was then credited back to the students in the form of "dining dollars" that could be spent only at on-campus dining outlets controlled exclusively by the food-service vendors for the universities - Aramark Educational Services, Inc., at UA; Compass Group, USA, Inc. (Chartwells) at Auburn; and Sodexo, Inc., at UAB. The trial court dismissed the three actions, and the students appealed. The Supreme Court consolidated the appeals for the purpose of writing one opinion and affirmed all three. The students sued the boards of trustees governing the universities and the food-service vendors, alleging that the dining-dollars programs violated: (1) state antitrust laws; (2) the Alabama Constitution inasmuch as it forbids the State from having an interest in a private enterprise; (3) the rule in 16-1-32(d) barring universities from charging excessive transaction fees to merchants that accept university-issued debit cards; and (4) the common-law prohibition on conversion. Because the boards of trustees are entitled to state immunity pursuant to section 14 of the Alabama Constitution, all claims against them were properly dismissed. The university administrators and foodservice vendors were entitled to immunity on the asserted antitrust claims as well, albeit state-action immunity as opposed to state immunity. Moreover, because the students lacked standing to pursue a cause of action for a violation of 16-1-32(d), and because the students did not and could not allege the necessary elements of a conversion claim, the trial court also properly dismissed the students' other claims. View "Vandenberg v. Aramark Educational Services, Inc." on Justia Law