Justia Alabama Supreme Court Opinion Summaries

A motorcyclist suffered severe injuries after crashing on Avenue V in Birmingham due to a defect in the road. He submitted a notice of claim to the City of Birmingham within six months as required by state law and later filed a negligence lawsuit, alleging the City failed to repair the defect after being notified. The key factual dispute involved whether the City had actual or constructive knowledge of the defect prior to the accident.The Jefferson Circuit Court reviewed the case and, after discovery, denied the City’s initial motion for summary judgment. The City later renewed its motion, attaching new evidence and seeking to strike some of the plaintiff’s evidence. The trial court struck several items, including an affidavit, an unsworn witness statement, and a patient-care report, but again denied summary judgment. The City’s motion for reconsideration was denied, prompting it to petition for a writ of mandamus.The Supreme Court of Alabama reviewed the petition, focusing on whether the City was entitled to municipal immunity. Applying a de novo standard, the court found that the admissible evidence did not create a genuine issue of material fact as to whether the City had actual or constructive knowledge of the defect. The court held that the plaintiff’s remaining evidence was speculative and insufficient to overcome the City’s prima facie case for immunity. The court granted the City’s petition, issued the writ of mandamus, and directed the trial court to vacate its order denying summary judgment and instead grant summary judgment in favor of the City. View "In re: Stoudmire v. City of Birmingham" on Justia Law

A group of individuals who had received traffic citations under a local ordinance enacted by the City of Tuskegee permitting automated photographic enforcement of traffic laws brought suit against the City, certain city officials, and JENOPTIK, the company involved in the installation and operation of the enforcement devices. The plaintiffs challenged the validity of the ordinance, raised constitutional concerns, and sought declaratory and injunctive relief as well as damages, including tort claims for negligence, invasion of privacy, and fraud. The City later enacted resolutions cancelling outstanding citations, refunding fines, and ultimately suspending enforcement of the ordinance.The case was initially filed in the Macon Circuit Court. The City and JENOPTIK moved to dismiss, arguing lack of a justiciable controversy, mootness, lack of standing, and other grounds, including lack of personal jurisdiction over JENOPTIK. The trial court denied these motions to dismiss, treating them as motions under Rule 12 and excluding extraneous materials, but did not provide detailed reasoning.On review, the Supreme Court of Alabama held that because the plaintiffs either paid the fines or failed to contest the citations under the administrative procedures provided in the ordinance, and because the City subsequently nullified the citations and provided for reimbursement, their claims challenging the legality of the ordinance were moot. The Court directed the trial court to dismiss those claims. However, the Supreme Court denied the petitions insofar as they sought dismissal of the plaintiffs’ tort claims, holding that the City and JENOPTIK did not demonstrate a clear right to mandamus relief on those claims at this stage. The Court likewise declined to dismiss the tort claims against JENOPTIK for lack of personal jurisdiction based on the current record. View "In re: Busby v. City of Tuskegee" on Justia Law

The plaintiffs, a trade association and a vape shop operator, filed suit challenging an Alabama law regulating electronic nicotine delivery systems (ENDS), which includes e-cigarettes and vapes. The law, effective June 1, 2025, established strict requirements for the sale of ENDS, including a product directory listing only approved products, mandates that products be manufactured in the United States or have federal FDA marketing authorization, and imposed significant penalties for violations. The plaintiffs claimed these regulations would cause them immediate and irreparable harm, including loss of profits, employees, and potential closure of their businesses due to prohibitions and penalties outlined in the law.The Montgomery Circuit Court initially granted a temporary restraining order (TRO) in favor of the plaintiffs, finding they would suffer irreparable harm and had no adequate remedy at law because the State defendants were protected by sovereign immunity. After a hearing, the court denied the plaintiffs’ motion for a preliminary injunction but extended the TRO pending appeal. The State defendants appealed, challenging the plaintiffs’ standing, while the plaintiffs cross-appealed the denial of the preliminary injunction.The Supreme Court of Alabama reviewed both appeals. It held that the plaintiffs had standing, as they faced concrete, particularized, and actual harm directly resulting from the enforcement of the Alabama law. However, the Court found the plaintiffs did not demonstrate a reasonable likelihood of success on the merits of their constitutional claims, including implied preemption and dormant Commerce Clause challenges. The Court determined that the Alabama Act was not preempted by federal law and served legitimate state interests related to health and safety. Therefore, the Supreme Court of Alabama affirmed the trial court's denial of the preliminary injunction. View "Spencer v. Vapor Technology Association" on Justia Law

A woman was seriously injured as a passenger in a car accident in Montgomery County, Alabama. She first received treatment at one hospital and was then transferred to another for further care. Both hospitals, which are affiliated with public entities, filed statutory hospital liens in probate courts to secure payment for her medical expenses from any settlement or recovery she might obtain related to her injuries. The total amount of the liens exceeded the amount available from the car owner’s insurance, which provided $75,000 in coverage. The woman settled with the insurance company and received a portion of the proceeds, with the rest held by her attorney pending resolution of the hospital liens.Afterward, she filed an action in the Montgomery Circuit Court, seeking interpleader and declaratory relief to determine the validity and amounts of the hospitals’ liens. One hospital, the University of South Alabama Health University Hospital, argued it was immune from suit under Article I, § 14, of the Alabama Constitution because it is a state agency. The trial court agreed, found that the state hospital was a necessary party, and dismissed the claims against both hospitals with prejudice, concluding it lacked subject-matter jurisdiction.The Supreme Court of Alabama reviewed the dismissal de novo. It held that an interpleader action brought under Rule 22 of the Alabama Rules of Civil Procedure to resolve the validity and amount of hospital liens does not implicate state immunity and does not deprive the trial court of jurisdiction, even when a state entity is named as a defendant. The Court reversed the trial court’s dismissal and remanded the case for further proceedings, allowing the plaintiff’s interpleader claim to go forward. View "Wood v. Health Care Authority for Baptist Health" on Justia Law

An individual sought appointment to a municipal position as Park and Recreation Director in a city, claiming the support of a majority of the city's separately incorporated Public Park and Recreation Board. Despite this support, the mayor appointed a different candidate. The individual then filed suit against the city, the mayor, the city administrator, and the Board, asserting that the city officials had improperly prevented the Board from exercising authority to select the Park and Recreation Director. The plaintiff based his claims on statutes granting certain employment powers to public park boards and on the Board’s bylaws, which he argued gave the Board authority over the director’s appointment.In the Jefferson Circuit Court, the defendants moved to dismiss the complaint. The circuit court granted the motions, finding that the plaintiff failed to state a claim against the City, that the mayor and administrator had state-agent immunity, and that there was no alleged wrongdoing by the Board. After the plaintiff unsuccessfully sought to alter or amend the judgment, he appealed.The Supreme Court of Alabama reviewed the case under the standard that requires viewing the complaint’s allegations in the plaintiff’s favor to determine if any set of facts could entitle him to relief. The Court held that the plaintiff lacked standing to sue the Board because he did not allege any actionable injury caused by the Board; the injury he suffered—failure to be hired—was attributable to city officials, not the Board. As for the city defendants, the Court found the plaintiff failed to state any valid legal claim, as the authority to appoint the city’s Park and Recreation Director resides with the mayor by statute, not the Board. Accordingly, the Supreme Court of Alabama affirmed the circuit court’s dismissal of the complaint. View "Wilder v. The City of Hoover" on Justia Law

Three individuals, Barbara Moore, Vanessa Reed, and Christine Burrell, served as members of the Lipscomb City Council, each representing a different district. After a city council meeting in May 2025, the council rejected a proposed redistricting plan and resolved to keep district boundaries unchanged. However, in the August 2025 municipal election, the election was conducted using the rejected redistricting map. Despite this, the three council members were sworn into office for their respective districts under the original boundaries. Mayor Robin Sims, claiming the council members no longer met residency requirements due to the district lines used in the election, filed for a temporary restraining order (TRO), a permanent injunction, and a writ of quo warranto, seeking their removal from office.The Jefferson Circuit Court, Bessemer Division, issued the TRO, then granted the writ of quo warranto and the permanent injunction, finding that the council members did not meet the statutory residency requirements and declaring their seats vacant. The court denied the council members’ motion to dismiss and their subsequent postjudgment motion, holding that they were unlawfully occupying their seats. The court also denied their request to stay enforcement of its judgment pending appeal.On appeal, the Supreme Court of Alabama reviewed whether the trial court had subject-matter jurisdiction. The Supreme Court held that the trial court lacked subject-matter jurisdiction because the statutory requirement that an informant provide security for costs at the commencement of a quo warranto action was not satisfied. The bond posted was solely for the injunction, not for the quo warranto proceeding. Because this requirement is jurisdictional, the trial court’s judgment was void. The Supreme Court of Alabama reversed the judgment and remanded the case with instructions for the trial court to vacate its judgment. View "Moore v. State of Alabama ex rel. Mayor Sims" on Justia Law

In this matter, a member of the University of Alabama’s men’s basketball team, Kai Spears, brought suit against The New York Times Company after it published articles erroneously identifying him as the unidentified passenger in a car at the scene of a high-profile shooting. The Times based its reporting on information from two confidential sources. Spears, who was not in the car, alleges that The Times failed to use reasonable care in publishing false and damaging statements about him. During litigation in the United States District Court for the Northern District of Alabama, Spears sought discovery to uncover the identities of the sources and related information. The Times resisted, invoking Alabama’s “shield statute,” which protects journalists from being compelled to reveal confidential sources.The United States District Court for the Northern District of Alabama certified two questions to the Supreme Court of Alabama concerning the scope of the state’s shield statute. The first question asked whether the statute protects the identity of a source when information is published online. However, as Spears conceded that the print publication of the article triggered the statute’s application, the Supreme Court of Alabama declined to answer this question, finding it irrelevant to the case.The Supreme Court of Alabama addressed the second certified question, which asked whether the shield statute protects any and all information that could reasonably lead to the identification of a protected source. The Court held that Alabama’s shield statute does not extend so broadly. Instead, it protects only information that would inevitably reveal the identity of a confidential source. Thus, information that could merely “reasonably lead” to the identification of a source is not covered. The Court declined to expand the statute’s protections beyond its plain language and expressly limited the privilege to “source-identifying” information whose disclosure would make identifying the source unavoidable. View "The New York Times Company v. Spears" on Justia Law

A woman called 911 to request a welfare check on her elderly neighbors’ home after noticing an unfamiliar vehicle and a young Black male there while the neighbors were out of town. When Officer Smith of the Childersburg Police Department arrived, he found a man watering flowers and asked if he lived at the house. The man, who identified himself as Pastor Jennings and said he lived across the street, explained he was watching the house for the neighbors. When asked for identification, Jennings became agitated and refused to provide any. Other officers arrived, and after Jennings repeatedly refused to further identify himself, he was arrested and charged with obstructing a governmental function.After the charge was dismissed, Jennings sued the officers and the City of Childersburg in the United States District Court for the Northern District of Alabama, alleging unlawful and retaliatory arrest under federal law and false arrest under state law. The district court granted summary judgment and dismissal in favor of the officers and the City, finding that Jennings violated Alabama’s stop-and-identify statute, Ala. Code § 15-5-30, by refusing to give his complete name. The United States Court of Appeals for the Eleventh Circuit reversed, relying on a prior interpretation of the statute that prohibited officers from demanding physical identification. On remand, the district court found the law’s interpretation uncertain and certified a question to the Supreme Court of Alabama.The Supreme Court of Alabama held that Ala. Code § 15-5-30 does not prohibit law enforcement officers, during a valid Terry stop, from requesting physical identification if a suspect gives an incomplete or unsatisfactory oral response regarding their name and address. The court clarified that suspects must provide sufficient identifying information and that failure to do so can constitute a violation of Alabama law. View "Jennings v. Smith" on Justia Law

Two sisters, aged twelve and nine, were sexually abused by their tutor during sessions at public libraries owned by two Alabama municipalities in 2017. The abuse was witnessed by library employees who allegedly failed to intervene or report the misconduct. The sisters disclosed the abuse to their mother later that year, prompting a police report. In 2023, the tutor was convicted of sexual abuse. In 2024, the sisters and their mother sued the municipalities, asserting negligence in failing to respond to the abuse.The initial complaint named nonprofit corporations associated with the libraries as defendants but was amended to substitute the municipalities themselves. Prior to filing the amended complaint, the plaintiffs served notices of claim to each municipality, but these were submitted more than six years after the alleged tortious conduct. Both the City of Irondale and the City of Birmingham moved to dismiss, arguing noncompliance with Alabama Code § 11-47-23, which requires notice of claim against a municipality within six months of claim accrual. The Jefferson Circuit Court granted their motions, dismissing the claims.On appeal, the Supreme Court of Alabama considered whether minors are exempt from the six-month notice requirement under § 11-47-23. The plaintiffs argued that minority status should toll the notice period, referencing statutory provisions that extend the time for filing suit by minors. The Supreme Court of Alabama held that § 11-47-23 contains no exception for minors and that the statutory tolling provision applies only to statutes of limitations, not notice-of-claim statutes. The court affirmed the Jefferson Circuit Court's dismissal of the claims against both municipalities, holding that minors are subject to the same notice requirements as adults under Alabama law. View "A.G.R. v. The City of Irondale" on Justia Law

A municipal water and gas board entered into four contracts with a contractor to replace and expand gas lines in and around a city. The total project cost exceeded $4 million, and the contractor began work after being the sole bidder for each project phase. After paying the contractor over $2.8 million, the board ceased payments, leaving over $800,000 due for completed work. The board asserted it could not continue payments because the advertisement for sealed bids had not strictly complied with the version of the applicable Alabama statute in effect at the time the bids were solicited. The contractor then sued the board for breach of contract and other claims.The Franklin Circuit Court granted summary judgment for the board, finding, in effect, that strict compliance with the statutory advertising requirements was necessary and that the contracts were void due to noncompliance. The trial court denied the contractor’s postjudgment motion, and the contractor appealed.The Supreme Court of Alabama reviewed the case de novo. It held that substantial compliance, rather than strict compliance, with the advertising requirements for public works contracts under the relevant statute can satisfy the law’s objectives. The court distinguished this situation from prior precedent where there was a complete absence of competitive bidding and evidence of favoritism or corruption. Here, there was no such evidence, and the board had taken affirmative steps to advertise, including publication and online postings. The court concluded that the contractor presented substantial evidence of substantial compliance, creating a genuine issue of material fact. The Supreme Court of Alabama reversed the summary judgment and remanded the case for further proceedings. View "Pinpoint Locating, Inc. v. The Water Works and Gas Board of the City of Red Bay" on Justia Law