Justia Alabama Supreme Court Opinion Summaries

Kevin Kendrick, as director of compliance at Alabama State University (ASU), appealed the grant of summary judgment ordering him to provide The Advertiser Company d/b/a The Montgomery Advertiser ("the Advertiser") with redacted copies of each "request for reduction/cancellation of athletic financial aid" form submitted to the director involving the ASU football program since December 15, 2014. A reporter for the Advertiser initially sent a written request for the forms to the school's media relations director spoke. The media relations director to the reporter by telephone, advising the reporter that because the forms contained sensitive personal student information, the forms would be heavily redacted. The reporter emailed the media relations director stating that he would "take just the list of names of players whose scholarships have been revoked since December [2014]." Later that day, the media relations director, under advice of university counsel, informed the reporter he could not even provide a list of names, citing privacy concerns under the Family Educational Rights and Privacy Act of 1974 (FERPA). Legal counsel for the Advertiser and legal counsel for ASU exchanged correspondence regarding whether the financial aid forms were subject to disclosure. When the parties could not agree, the Advertiser filed a declaratory judgment suit and petition for a writ of mandamus to compel the records' disclosure. The Supreme Court, after review, reversed and remanded the grant of summary judgment: "We commend the trial court for its efforts to comply with both FERPA and the Open Records Act by requiring ASU to redact the requested financial-aid forms in the manner it directed. However, the release of the redacted financial-aid forms to the Advertiser would nonetheless disclose information that is protected by FERPA, and the Advertiser did not argue that the release of the redacted financial-aid forms is authorized by any other exception in FERPA. Because FERPA prohibits the very release of the redacted financial-aid forms and because FERPA takes precedence over the Open Records Act, the director is entitled to a summary judgment." View "Kendrick v. The Advertiser Company" on Justia Law

Cathy Trimble and Ida Longmire petitioned for a writ of mandamus to direct the Perry Circuit Court to enter a summary judgment in their favor on certain claims asserted against them by Crystal Lewis, individually and by and through her mother and next friend, Mary Lewis. In October 2012, Crystal was a 12th-grade student at Francis Marion High School. The school system was covered by Section 504 of the Rehabilitation Act, which generally required a school district to provide reasonable accommodations to assist any child deemed to have a "disability" as that term is defined by the Act. Crystal had a medical condition that required the Perry County public school system to provide her with certain special accommodations. Longmire was an English teacher at Francis Marion High School and also served as committee-member secretary for the school's Section 504 special-accommodations meetings. Longmire prepared an updated report of the special accommodations required by Section 504 intended to inform particular teachers of the 504 accommodations for specific students. Longmire placed a copy of the report in sealed envelopes, which were to be hand delivered to the teachers. Longmire asked Trimble, acting principal of the school, about distributing the envelopes. Trimble assigned a student office aide the task of delivering the envelopes to the teachers. Rather than delivering the envelopes as instructed, the student office aide opened one of the sealed envelopes and read about Crystal's medical condition. She shared that information about Crystal's medical condition with other students. Crystal commenced this action against Longmire, Trimble, the student office aide, the Perry County Board of Education, "Francis Marion High School," and other school administrators. In her complaint, Crystal alleged that she has faced ridicule, harassment, and bullying as a result of the dissemination of her confidential medical information. She asserted claims of negligence, wantonness, nuisance, breach of contract, and invasion of privacy against each defendant and claims of negligent hiring, training, and supervision against all the defendants except the student office aide and Longmire. Longmire and Trimble moved for a summary judgment on the ground that they were entitled to State-agent immunity as to all claims asserted against them by Crystal. The Supreme Court determined that Longmire and Trimble were entitled to State-agent immunity. The trial court was ordered to vacate its order denying the motion for a summary judgment filed by Longmire and Trimble and to enter a summary judgment in their favor. View "Ex parte Trimble & Longmire" on Justia Law

Before 2010, Azin Agah was employed at the University of South Alabama ("USA") as a professor engaged in scientific research. Agah's position was a tenure-track professorship. In early 2010, USA's vice president for Health Sciences, Ronald Franks, notified Agah that she would not be reappointed to her professorship because of alleged research misconduct. Agah sued Amber Bartlett and Julio Turrens. Bartlett was a student of Agah's, and she reported her concerns regarding Agah's research to Turrens, who was a professor and associate dean at USA. Agah sought compensatory and punitive damages against the defendants for the alleged theft and conversion of her computerized electronic-research data and the alleged theft and conversion of her animal-research logbook and intentional interference with a contractual property right arising out of the termination of her employment by USA. Agah also sued "R.T., W.B.D., R.F.," whose names were "known and unknown" and who, according to Agah, played a role in the theft of her research, "the defamation of the Plaintiff's character, and the intentional interference with the Plaintiff's property right of employment." After the lawsuit had been filed, and after a period of discovery, Agah gave names to the initials previously listed in her original complaint: Richard Talbott, William Brad Davis, and Ronald Franks. She would also add Dusty Layton and others who were involved in the review of Agah's research. The petitioners (Talbott, Ballard, and Layton) each filed a motion to dismiss. Each argued, among other things, that, with the exception of the conversion and detinue claim, Agah's remaining claims accrued in February 2010 when her employment was terminated, that Agah's amended complaint did not relate back to the original complaint, and that the remaining claims asserted in the amended complaint were time-barred. They also argued that they were entitled to immunity with respect to Agah's claims alleging tortious interference with contractual rights, tortious violations of her procedural and substantive due-process rights, and conversion and detinue, because, they argued, they were sued in their individual capacity and lacked the authority to grant Agah her requested injunctive relief. Following a hearing, the trial court denied all three motions. The Supreme Court reversed, finding that petitioners demonstrated a clear legal right to the dismissal of Agah's amended complaint against them. Agah's amended complaint did not relate back to her original complaint; thus, all of her claims against the petitioners, with the exclusion of her conversion and detinue claim, were barred by the statute of limitations. Furthermore, Agah's conversion and detinue claim against the petitioners in their individual capacities sought relief that the petitioners could not provide. Therefore, the trial court was directed to vacate its order denying the petitioners' motion seeking dismissal of the claims against them. View "Ex parte Richard Talbott et al." on Justia Law

Brenda Franks was a former nontenured employee of the Choctaw County Public School System. Before the 2008-2009 school year, Franks had been employed as a full-time counselor in the school system for three years when her contract was not renewed. For the 2008-2009 school year, Franks was offered and accepted a part-time, temporary position as a vocational counselor starting in February 2009. She signed an employment contract acknowledging that the position was temporary. She also signed a "Letter of Understanding Concerning Temporary Employment." Franks worked pursuant to the contract for five months. The superintendent notified Franks, in writing, of her intention to recommend that the School Board members cancel the contract because of a "justifiable decrease in jobs in the system." The Board members approved the recommendation to cancel the contract. Franks did not contest the cancellation. In July 2010, the Board members posted a vacancy for a business-education teacher. Franks applied for the position, but was not hired. Franks sued the Board and Superintendent, asserting that the Board members had terminated her employment based on a reduction in force ("RIF"), but that she was entitled to be hired for the teaching position pursuant to the RIF policy. Franks sought to be instated to that position, with backpay, interest, and restoration of progress toward tenure. However, Franks died prior to the conclusion of this suit. Petitioners Ronald Hampton, Darry Phillips, Wayne Taylor, Isaac Johnson, and Sharon Sheppard, the individual members of the Choctaw County Board of Education, and Sue Moore, the superintendent of the Choctaw County Public School System sought an order compelling the Choctaw Circuit Court to vacate its denial of their summary-judgment motion and to enter summary judgment in their favor on the ground that the trial court lacked subject-matter jurisdiction over the claims because of plaintiff's death and the petitioners' immunity. The Supreme Court concluded that the superintendent and the Board members demonstrated immunity and established a clear legal right to a summary judgment on the claims asserted against them in their official capacities. Therefore, the Supreme Court granted the petition and issued a writ directing the Choctaw Circuit Court to vacate its order denying the petitioners' summary-judgment motion and to enter a summary judgment on all the claims asserted against the superintendent and the Board members. View "Ex parte Ronald Hampton, et al." on Justia Law

The Escambia County Board of Education terminated the employment of John Lambert, a tenured teacher, as the band director at Flomaton High School for leaving a pistol in his school office, which was locked. During the course of his teaching career and military service, Lambert was never charged with neglect of duty, insubordination, or failure to perform duties in a satisfactory manner. Before this incident, no school board had ever taken disciplinary action against Lambert, nor had Scott Hammond, the principal of Flomaton High School, ever disciplined Lambert. Before getting on a bus for a band trip where the students were waiting for Lambert to join them, Lambert placed a small bag on the desk in his office. The bag contained personal items, including clothing, tools, Lambertís checkbook, and 10 20-dollar bills in a folded bank envelope. The bank envelope was in the side pocket of the bag, which was zipped. Lambert placed the bag in his office because he did not want to leave it in his truck overnight while he was away on the trip. According to Lambert, he forgot that a loaded .380 automatic pistol and an additional loaded magazine were in a small case at the bottom of the bag. Both the case containing the pistol and the bag were zipped. The bag was black, and it was impossible to identify the contents of the bag from the exterior of the bag. Lambert, who had a permit for the pistol, testified that both his office door and the door to the band room were locked when he left for the band contest at approximately 8:00 a.m. Around noon that same day, a school custodian notified school administrators that a gun was found on school premises. Only Lambert, the custodian, and the principal had keys to Lambert's office. Lambert acknowledged the pistol was his, and discovered that $80 was missing from the bag. Lambert was placed on administrative leave, then later terminated. He appealed the Board's decision. The Court of Civil Appeals affirmed the decision of the hearing officer. The Supreme Court, however, reversed. "In light of the fact that this Court has resolved, as a material question of first impression, the standard of review a hearing officer is to apply to an employer's decision to terminate the employment of a tenured teacher, we reverse the judgment of the Court of Civil Appeals and remand the cause to that court to, in turn, reverse the judgment of the hearing officer and remand the cause to him with instructions to review the sanction imposed against Lambert under the arbitrary-and-capricious standard of review as that standard [was] articulated in this opinion." View "Ex parte John Lambert." on Justia Law

The issues presented in three appeals (consolidated for review) were ones of first impression to the Alabama Supreme Court regarding the state Accountability Act (AAA). Plaintiffs Daniel Boyd (superintendent of the Lowndes County Public School System), Anita Gibson (a teacher and president of the Alabama Education Association) and Senator Quinton Ross, Jr. (representative of the 26th District) sued Julie Magee in her official capacity as the Commissioner of Revenue, and Thomas White, Jr. in his official capacity as the state Comptroller. Plaintiffs challenged the constitutionality of the AAA under certain provisions of the Alabama Constitution of 1901 that allowed the substitution of House Bill (HB 84), the creation of certain tax credits, the appropriation of funds for those credits, the repeal of certain tax credits, and the creation of new debt - all in relation to education funding in the State of Alabama. The circuit court entered an order in favor of plaintiffs as to their first eight counts in their complaint. With regard to Counts IX and X, the court concluded the issues were moot. The circuit court then enjoined enforcement of the AAA. The State defendants moved to stay the circuit court order, then appealed. The Supreme Court, after careful consideration of the legislation at issue and the circuit court's order, affirmed in part, reversed in part and remanded. The Court found: (1) no subsequent act of the Legislature mooted any issue presented here; and (2) the AAA was constitutional with regard to all of plaintiffs' allegations that it was not. The case was remanded for further proceedings on those issues deemed moot by the circuit court; the court was affirmed in all other respects. View "Magee v. Boyd" on Justia Law

Chad Jones petitioned the Supreme Court for a writ of mandamus to direct the Circuit Court to vacate its order denying his motion for a summary judgment in an action filed against him by Latonya Hall, individually and as mother and next friend of Demetrius Hall, a minor, and Maurice Caffie, individually (collectively referred to as "Hall"), and to enter a summary judgment in his favor on the basis of State-agent immunity. Jones was employed as a physical-education teacher at Gresham Middle School and Demetrius Hall and Michael Boyd were students. A fight between the young men broke out during a school basketball game. According to Demetrius, he was guarding Boyd tightly when Boyd became angry and threw the basketball at him, striking him in the face with the ball. Demetrius responded by pushing Boyd and throwing a punch. After the two exchanged insults, another student unexpectedly shoved Demetrius into Boyd, and Boyd responded by "slamming" Demetrius into some nearby metal stairs and striking him in the head. Demetrius was seriously injured as the result of the altercation. Jones contends that he was at the opposite end of the gym when the altercation occurred. Hall sued Jones, Sokol, and Sammy Queen, (another school physical-education teacher) asserting claims of negligence and wantonness and alleging that the defendants had breached their duty to reasonably supervise Demetrius and Boyd by leaving them unattended for an extended length of time. Concluding that Jones failed to demonstrate that he had a clear legal right to the relief sought, the Supreme Court denied his petition for a writ of mandamus. View " Hall v. Jones" on Justia Law

The Bessemer City Board of Education and Davis Middle School petitioned the Supreme Court for a writ of mandamus to direct the Circuit Court to vacate its order denying the petitioners' motion to dismiss the claim filed against them by John Doe, a minor, by and through his next friend, W.A. ("Doe"), and to enter an order dismissing with prejudice the claim against petitioners. The matter stemmed from a claim of negligence Doe raised against the school; Doe claimed he had been sexually abused by an unidentified person as a result of the negligence of petitioners. The Circuit Court denied petitioners motion based on qualified immunity grounds. After review, the Supreme Court found that petitioners demonstrated they were entitled to absolute immunity from Doe's action against them. Therefore the Court granted their petition and issued the writ. View "Ex parte Bessemer City Board of Education" on Justia Law

In these consolidated appeals, Carol Perdue, individually and as next friend and guardian of her daughter, Anna; William D. Motlow, Jr.; and Shane Sears (hereinafter collectively referred to as "the objectors"), all of whom were objecting class members in class-action litigation related to the Alabama Prepaid Affordable College Tuition ("PACT") Trust Fund a/k/a The Wallace-Folsom Prepaid College Tuition Trust Fund, appealed the trial court's judgment that approved a class-action settlement concluding the litigation. The objectors largely complained that as contributors or beneficiaries of the PACT fund, it was being mismanaged and underfunded to their detriment. While the case was pending, the Alabama Legislature changed the laws directly impacting the management and funding of the PACT program. The PACT Board responded to the change in the law by moving to dismiss the objectors' suit as moot. The issues on appeal before the Supreme Court involved terms of the settlement agreement: the objectors contended that the trial court permitted language in the agreement that ran afoul of the changed laws and disregarded objections of the complaining members of the class. Upon review, the Supreme Court vacated the trial court's judgment and remanded the case: "[t]he scope of the objections in the trial court was not the narrow question whether the order should bind only the objectors, but, on the contrary, the issue presented [was] the broader question whether the trial court's judgment approving the settlement agreement [was] due to be affirmed. . . . the objectors are allowed to appeal that aspect of the trial court's order that affects them - 'the [circuit court's] decision to disregard [their] objections.' If the judgment [was] affirmed, the settlement agreement affects them in that it binds them, as members of the class, to terms of a settlement agreement inconsistent with 16-33C-19." View "Perdue v. Green" on Justia Law

The Montgomery County Board of Education (the Board), several of its members, and a teacher in the school system petitioned the Supreme Court for a writ of mandamus to direct the circuit court to vacated its order that denied their motion for summary judgment. Third-grade student "S.K." went to the restroom with two friends. Her teacher did not accompany them. S.K. claims that when she attempted to leave the restroom stall, the door jammed. She tried to climb over the door to get out of the stall but slipped and fell, cutting her face on a metal hanger on the back of the door. S.K. (by and through her mother Tetrina Capehart) sued the Board, its members individually and in their official capacities, and the teacher asserting negligence and wantonness claims, and sought compensatory and punitive damages. The Board and teacher argued that there were no genuine issues of fact, and that S.K. was contributorily negligent from "playing" in the restroom. The circuit court denied the Board's motion. Upon review, the Supreme Court concluded the Board demonstrated that under the state constitution, it had absolute immunity from suit for claims asserted against it. The Court granted the Board's petition and issued the writ to direct the circuit court to rule in the Board's favor. View "In re: S.K." on Justia Law