Justia Alabama Supreme Court Opinion Summaries

Willie C. Scott signed a promissory note on May 22, 2018, promising to pay $67,000 to Jimmy C. Scott by March 24, 2020. The note detailed amounts borrowed on three separate dates. Willie passed away on November 20, 2019, and Jeanetta C. Scott, as administratrix of his estate, denied the allegations in Jimmy's complaint, asserting that Willie had fulfilled his obligations under the note.Jimmy filed a complaint in the Pike Circuit Court on October 13, 2021, seeking repayment. Jeanetta contested the claim, and the case was consolidated with another related to the administration of Willie's estate. Jimmy moved for summary judgment, supported by affidavits from himself and two witnesses who attested to witnessing Willie sign the note. Jeanetta opposed the motion, providing affidavits from herself and another individual, both asserting that the signature on the note was not Willie's.The Pike Circuit Court initially denied Jimmy's motion for summary judgment but later granted it after a renewed motion and hearing. Jeanetta's subsequent motion to set aside the summary judgment was denied, leading to this appeal.The Supreme Court of Alabama reviewed the case and found that the circuit court had improperly made credibility assessments in granting summary judgment. The court noted that there was a genuine issue of material fact regarding the authenticity of Willie's signature on the promissory note, which should be resolved by a jury. Consequently, the Supreme Court of Alabama reversed the circuit court's summary judgment in favor of Jimmy and remanded the case for further proceedings. View "Scott v. Scott" on Justia Law

In 2020, Sarah E. Martin was injured in a car accident involving an 18-wheel tractor-trailer driven by Charles Streeter, an employee of Al-Amin Brothers Transportation, LLC. Martin sued the LLC, several individuals, and 18 fictitiously named defendants. In January 2023, Martin settled with the original defendants, agreeing to release them and related parties from any claims arising from the accident. Subsequently, Martin amended her complaint to add PEI Ohio, Inc. and Premium Transportation Group, Inc. (the corporations) as defendants, alleging various negligence and breach of contract claims.The Jefferson Circuit Court enforced the settlement agreement in favor of the corporations, dismissed Martin's third amended complaint, and awarded attorney fees to the corporations. Martin filed a fourth amended complaint, which remains pending. The circuit court certified its orders as final under Rule 54(b), Ala. R. Civ. P., and Martin appealed both the enforcement of the settlement and the attorney fee award.The Supreme Court of Alabama reviewed the case and determined that the circuit court exceeded its discretion in certifying the orders as final under Rule 54(b). The court found that the adjudicated and unadjudicated claims were closely related, the need for review might be mooted by future developments in the circuit court, and there was a possibility of having to consider the same issue again, particularly regarding attorney fees. Consequently, the Supreme Court of Alabama dismissed Martin's appeals, emphasizing the preference to avoid piecemeal litigation and the need for a final judgment on all pending claims before appellate review. View "Martin v. PEI Ohio, Inc." on Justia Law

The case involves a dispute between Hyundai Construction Equipment North America, Inc. and Hyundai Heavy Industries Co., Ltd. (collectively "Hyundai") and Southern Lift Trucks, LLC ("Southern"). Southern sued Hyundai after Hyundai terminated one of their agreements and appointed another dealer in Southern's sales territory. Southern's claims included breach of contract, tort claims, and claims under the Alabama Heavy Equipment Dealer Act (AHEDA). The agreements between the parties included an arbitration clause for resolving disputes.The Washington Circuit Court initially denied Hyundai's motion to compel arbitration. Hyundai appealed, and the Supreme Court of Alabama held that all of Southern's claims, except for portions of the declaratory-judgment claim relating to the enforceability of the dealer agreements, should be sent to arbitration. The trial court then entered an order compelling arbitration for all claims except the declaratory-judgment claim. Southern did not initiate arbitration and instead filed a motion to enjoin or stay the arbitration proceedings initiated by Hyundai.The Supreme Court of Alabama reviewed the trial court's order enjoining the arbitration. The court held that the arbitration provision required all disputes to be resolved by arbitration, except for declaratory judgments on the enforceability of any provision of the agreements. The court found that the trial court erred in enjoining the arbitration, as the arbitration provision did not prevent arbitrators from adjudicating disputes over the agreements' enforceability. The court emphasized that the Federal Arbitration Act requires arbitration of all claims except for the non-arbitrable portions of the declaratory-judgment claim and that judicial economy or the possibility of inconsistent results does not justify staying arbitration.The Supreme Court of Alabama reversed the trial court's order enjoining the arbitration and remanded the case for further proceedings consistent with its opinion. View "HD Hyundai Construction Equipment North America, Inc. v. Southern Lift Trucks, LLC" on Justia Law

Digital Forensics Corporation, LLC ("DFC") was retained by King Machine, Inc. and Hartford Fire Insurance Company to perform electronic-discovery services related to a discovery order in litigation in the Etowah Circuit Court. The plaintiffs alleged that DFC misrepresented its capabilities on its website and through its representatives, leading them to believe DFC could perform the required services. Despite paying DFC $35,291.93, the plaintiffs claimed DFC failed to deliver the data in a usable format, resulting in additional costs and sanctions totaling $50,291.93, plus $107,430.44 in attorneys' fees and expenses.The plaintiffs filed a lawsuit in the Jefferson Circuit Court, alleging breach of contract and fraud in the inducement. DFC removed the case to federal court, which later remanded it back to the circuit court. DFC then filed a motion to compel arbitration based on a clause in their agreement, which included a multi-step dispute resolution process culminating in binding arbitration. The plaintiffs opposed the motion, arguing that the arbitration clause was fraudulently induced.The Jefferson Circuit Court denied DFC's motion to compel arbitration. DFC appealed to the Supreme Court of Alabama, arguing that the arbitration provision should be enforced. The Supreme Court of Alabama reviewed the case de novo and determined that the plaintiffs' fraud claims were directed at the entire agreement, not solely the arbitration clause. Therefore, the allegations of fraud in the inducement did not provide a basis to avoid arbitration.The Supreme Court of Alabama reversed the circuit court's order denying DFC's motion to compel arbitration and remanded the case for further proceedings consistent with its opinion. View "Digital Forensics Corporation, LLC v. King Machine, Inc." on Justia Law

In January 2019, Raymond Robinson and his son sued Emerald Homes, L.L.C., and 21st Mortgage Corporation in the Baldwin Circuit Court. Robinson had contracted with Emerald to purchase a mobile home, financed by a loan from 21st Mortgage. After tearing down his existing house in preparation for the new mobile home, the loan was not completed, allegedly due to Emerald and/or 21st Mortgage's refusal to finalize the transaction. The complaint included claims of breach of contract, misrepresentation, suppression, and negligence, seeking compensatory and punitive damages.The trial court compelled arbitration for claims against Emerald and granted summary judgment in favor of 21st Mortgage on Raymond's claims. The case proceeded to a jury trial on Robinson's claims against 21st Mortgage. The jury found in favor of Robinson on promissory fraud and the tort of outrage, awarding him $2,980,000 in total damages. 21st Mortgage's post-trial motions, including for judgment as a matter of law (JML), were denied.The Supreme Court of Alabama reviewed the case. It held that Robinson did not present substantial evidence of promissory fraud, as he failed to prove that 21st Mortgage had no intention to perform the loan promise at the time it was made or intended to deceive him. The court also found that Robinson did not meet all the conditions required for the loan, and the failure to close the loan was not due to any fraudulent intent by 21st Mortgage.Regarding the tort of outrage, the court held that the conduct of 21st Mortgage did not meet the extreme and outrageous standard required for such a claim. The court reversed the trial court's judgment and remanded the case for further proceedings consistent with its opinion. View "21st Mortgage Corporation v. Robinson" on Justia Law

In January 2023, the Keenums and Karibu Home Builders, LLC entered into a real-estate sales contract where the Keenums agreed to sell seven lots and construct a paved road before the closing date. The contract included dispute-resolution provisions for mediation and arbitration. The Keenums did not complete the road or appear for the closing. Karibu sued for specific performance and damages, claiming the Keenums breached the contract. The Keenums argued the contract was void due to Karibu's failure to meet obligations and the requirement for mediation and arbitration.The Colbert Circuit Court granted summary judgment in favor of the Keenums, dismissing the case with prejudice. The court concluded it lacked subject-matter jurisdiction due to the contract's mediation and arbitration provision, implying Karibu should have filed directly with the American Arbitration Association.The Supreme Court of Alabama reviewed the case de novo and found that the trial court erred in concluding it lacked jurisdiction. The court held that the trial court had the authority to determine whether the mediation and arbitration provision applied and should have compelled arbitration rather than dismissing the case. The summary judgment was reversed, and the case was remanded for further proceedings consistent with the opinion. View "Karibu Home Builders, LLC v. Keenum" on Justia Law

In May 2022, Jerry & John Woods Construction, Inc. ("Woods Construction") entered into a contract with John David Jordan and Carol S. Jordan to construct a house and a metal building. Woods Construction claimed the Jordans failed to pay for the work performed, leading the company to sue them in the Dallas Circuit Court for breach of contract and unjust enrichment. The Jordans moved to dismiss or for summary judgment, arguing that Woods Construction's lack of a required residential-home-builder's license barred the company from bringing civil claims. They also filed counterclaims alleging improper and negligent work by Woods Construction.The Dallas Circuit Court denied the Jordans' motion to dismiss but later granted their motion for summary judgment, finding that Woods Construction, as an unlicensed residential home builder, was barred from enforcing the construction contract under § 34-14A-14(d) of the Alabama Code. The court also declared Woods Construction's "Notice of Lis Pendens/Lien" null and void. The court certified its judgment as final under Rule 54(b), despite the Jordans' counterclaims remaining pending.The Supreme Court of Alabama reviewed the case and determined that the Rule 54(b) certification was improper. The court noted that the claims and counterclaims were closely intertwined, as both concerned the same contract and construction work. Additionally, the resolution of the Jordans' counterclaims could potentially moot Woods Construction's claims. Therefore, the court concluded that the circuit court exceeded its discretion in certifying the judgment as final and dismissed the appeal for lack of a final judgment. View "Jerry & John Woods Construction, Inc. v. Jordan" on Justia Law

Hudgen LeBlanc and Jodi LeBlanc filed a complaint against Residence Doctor Home Inspection, LLC, and its owner-operator, Terry J. Holder, alleging negligence, wantonness, gross negligence, fraudulent/innocent misrepresentation, suppression, and breach of contract. The claims arose from a pre-purchase home inspection performed by Holder, which the LeBlancs claimed failed to report structural issues with the flooring of the home they purchased. Instead, the report only mentioned "microbial growth" on the floor joists and recommended hiring a mold-remediation specialist. After purchasing the home, the LeBlancs hired a mold-remediation specialist who discovered rotten floor joists, costing nearly $40,000 to repair.The St. Clair Circuit Court granted summary judgment in favor of the inspection company and Holder on the negligence and breach-of-contract claims and dismissed the fraud, suppression, and wantonness claims with prejudice. The court found that the LeBlancs failed to provide expert testimony to establish the applicable standard of care or Holder's breach of that standard, which was necessary to prove their claims.The Supreme Court of Alabama reviewed the case de novo. The court held that expert testimony is required to establish a home inspector's breach of the applicable standard of care, similar to other professionals such as real-estate appraisers, engineers, and architects. The LeBlancs did not present expert testimony or establish that the breach was so obvious that it did not require expert testimony. Consequently, the Supreme Court of Alabama affirmed the trial court's summary judgment in favor of the inspection company and Holder. View "LeBlanc v. Residence Doctor Home Inspection, LLC" on Justia Law

Shymikka Griggs filed a data-breach action against NHS Management, LLC, a consulting firm providing management services for nursing homes and physical-rehabilitation facilities. NHS collects sensitive personal and health information from employees, patients, and vendors. In May 2021, NHS discovered a cyberattack on its network, which lasted 80 days. NHS notified affected individuals, including Griggs, in March 2022. Griggs, a former NHS employee, claimed her personal information was found on the dark web, leading to credit issues, spam communications, and fraudulent activities.Griggs initially filed a class-action complaint in the United States District Court for the Northern District of Alabama but later dismissed it. She then filed a class-action complaint in the Jefferson Circuit Court in June 2023, alleging negligence, negligence per se, breach of contract, invasion of privacy, unjust enrichment, breach of confidence, breach of fiduciary duty, and violation of the Alabama Deceptive Trade Practices Act. NHS moved to dismiss the complaint, arguing lack of standing and failure to state a claim. The Jefferson Circuit Court dismissed Griggs's complaint with prejudice.The Supreme Court of Alabama reviewed the case and affirmed the circuit court's judgment. The court held that Griggs failed to sufficiently plead her claims. Specifically, she did not demonstrate that NHS owed her a duty under Alabama law, failed to establish proximate cause for her negligence per se claim, did not allege intentional conduct for her invasion-of-privacy claim, and did not show that she conferred a benefit on NHS for her unjust-enrichment claim. Additionally, the court found that breach of confidence is not a recognized cause of action in Alabama and that Griggs did not establish a fiduciary relationship between her and NHS. View "Griggs v. NHS Management, LLC" on Justia Law

John A. Daugherty, an attorney, filed a breach-of-contract claim against his former client, Molly Chew Baker, in the Jefferson Circuit Court. Daugherty and Molly had an agreement where Daugherty would help Molly collect alimony arrears from her ex-husband, Christopher, on a contingency-fee basis. Daugherty later agreed to represent Molly in additional matters related to her divorce, including a petition to modify alimony payments filed by Christopher. Molly eventually terminated Daugherty's services, and Daugherty sought to recover his fees through the court.The Jefferson Circuit Court dismissed Daugherty's complaint, concluding that the contingency-fee arrangement in the contract was against public policy under Rule 1.5(d)(1) of the Alabama Rules of Professional Conduct, which prohibits contingency fees in domestic relations matters involving alimony or support. The court also noted that the contract did not provide for compensation in the event of a settlement, which occurred when Molly and Christopher jointly dismissed their respective petitions.Daugherty appealed to the Supreme Court of Alabama, arguing that the contingency-fee arrangement was permissible under an exception for collecting alimony arrears after a completed divorce. However, the Supreme Court affirmed the lower court's decision, noting that Daugherty's representation extended beyond collecting arrears to include ongoing alimony matters, which did not fall under the exception. Additionally, Daugherty's claim for quantum meruit was not properly pleaded in the lower court and was inconsistent with his breach-of-contract claim. The Supreme Court concluded that the circuit court's judgment was correct and affirmed the dismissal of Daugherty's complaint. View "Daugherty v. Baker" on Justia Law