Justia Alabama Supreme Court Opinion Summaries

John Woodruff appealed a circuit court order dismissing his malicious-prosecution, false imprisonment, and tort-of-outrage claims against the City of Tuscaloosa ("the City") and several of its employees. On October 16, 2006, Woodruff went to the Tuscaloosa Police Department headquarters to resolve a warrant that had been sworn against him for harassing communications. After presenting himself, Woodruff was arrested and handcuffed by a Tuscaloosa police officer and told to wait until another officer could arrive to complete the booking process. While waiting in the public lobby of police headquarters, Woodruff became involved in a verbal altercation with an off-duty Tuscaloosa police officer, and he was subsequently charged by Officer Canterbury with disorderly conduct, another Class C misdemeanor. Woodruff was thereafter booked and transported to the county jail, where he was released on bond later that night. On October 19, 2006, Woodruff returned to the Tuscaloosa Police Department to file a written complaint regarding the events surrounding his arrest and booking on October 16. The Tuscaloosa Police Department ultimately determined that Woodruff's complaint was without merit. On November 15, 2006, Woodruff was convicted of disorderly conduct. He thereafter sought a trial de novo on the charge in Circuit Court; however, in December 2008, while the matter was still pending, Woodruff and the City apparently reached an agreement to nol-pros the charge if Woodruff would undergo counseling. On January 2, 2009, the disorderly conduct charge was formally dropped. On January 3, 2011, Woodruff filed the this action. Upon review, the Supreme Court concluded that it was "evident" that Woodruff did not state a claim upon which relief could be granted. The Court affirmed the circuit court in denying his claims. View "Woodruff v. City of Tuscaloosa" on Justia Law

Eliot Hoff appealed a circuit court order that remanded the administration of the conservatorship of his grandmother, Susan Bibb Kidd, to the Jefferson Probate Court. In 2006, the probate court adjudged Kidd to be an incapacitated person and appointed Mark Goolsby as conservator of her estate. Sometime in August 2008, Goolsby sold some personal property in Kidd's estate to Anita Kidd Goyer, one of Kidd's three daughters. When another of Kidd's daughters, Susan Louis Hoff, and her son Hoff found out about the sale, they filed an objection in the probate court. Meanwhile, on September 29, 2009, Kidd died. On February 21, 2011, the probate court issued an order that, among other things, approved the August 2008 sale of Kidd's personal property to Goyer. The Hoffs promptly moved the probate court to reconsider. An initial hearing on their motion was held on June 8, 2011; however, the matter was continued and another hearing scheduled for September 15, 2011. On June 24, 2011, Goolsby petitioned the probate court to be appointed administrator of Kidd's estate because he could not conduct business as conservator after her death. The Hoffs thereafter also filed a motion to continue the hearing scheduled for September 15, 2011. The probate court ruled on those motions, setting the hearing on the Hoffs' motion to reconsider and denying Goolsby's motion to be appointed administrator of Kidd's estate. Instead, the probate court, on its own motion, appointed attorney Elizabeth W. McElroy, the general administrator for Jefferson County, as administrator of Kidd's estate. Hoff appealed the order entered by the circuit court remanding the administration of the conservatorship of his grandmother to the probate court, arguing that he had properly petitioned for removal. Upon review of the matter, the Supreme Court concluded Hoff did not have standing to seek removal, that the circuit court's order of remand was properly entered. View "Hoff v. Goyer " on Justia Law

Defendant Amy Bishop Anderson petitioned the Supreme Court for a writ of mandamus to direct the Madison Circuit Court to compel the Office of Indigent Defense Services and the Comptroller's Office within the Department of Finance to comply with the circuit court's orders and disburse interim payments of fees to her retained experts. Upon review, the Supreme Court denied the petition. Anderson was indicted on charges of capital murder and attempted murder after she shot several of her colleagues during a biology-department faculty meeting at the University of Alabama in Huntsville in 2010. Defendant's defense counsel served notice that they indended to argue that Defendant was not guilty by reason of mental disease or defect. The circuit court entered an order granting defense counsel's ex parte motion for extraordinary expenses. The circuit court authorized defense counsel to retain the services of a neuropsychiatrist who evaluated Defendant, and ordered the comptroller to make immediate payment to cover the expert's retainer. According to Defendant, the expert began working on the case with a reasonable expectation of being paid at a later date. No payment was made. The Supreme Court concluded that while the circuit court entered the orders directing interim payments for Defendant's experts, Defendant did not show that the circuit court refused to enforce those orders. Based on this, Defendant did not satisfy her burden that the circuit court refused to enforce its orders. View "Alabama v. Anderson" on Justia Law

Defendant Sandoz, Inc. appealed a judgment entered on a jury verdict in favor of the State of Alabama. The State alleged at trial that Sandoz, a manufacturer of generic pharmaceuticals, purposely reported inflated pricing information for generic drugs in third-party publications and that the State, using those published prices, overpaid certain reimbursements to providers of prescription drugs made pursuant to the Medicaid program. The State thus sued Sandoz seeking damages under various theories of fraud. Previously, in "AstraZeneca LP v. Alabama," (41 So. 3d 15 (Ala. 2009)), the State unsuccessfully sued manufacturers of brand-name pharmaceuticals under the same theories. Because in this case, as in "AstraZeneca," the State knew that the prices reported by Sandoz were not what the State claims they should have been, Alabama law does not allow the State to claim that its reliance on that information was reasonable. Further, the State's reimbursement decisions were not based on the allegedly false information provided by Sandoz; instead, its decisions were based on policy concerns and certain requirements of the federal Medicaid program. Thus, as was the case in "AstraZeneca," the State's claims should not have been submitted to the jury, and Sandoz was entitled to a judgment in its favor. Therefore, the Supreme Court reversed the trial court's judgment and rendered judgment in favor of Sandoz. View "Sandoz, Inc. v. Alabama " on Justia Law

Defendant Amy Bishop Anderson petitioned the Supreme Court for a writ of mandamus to direct the Madison Circuit Court to compel the Office of Indigent Services and the Comptroller's Office within the state Department of Finance to comply with the circuit court's orders and disburse interim payments of fees to her retained experts. Anderson was indicted on charges of capital murder and attempted murder after she shot several of her colleagues during a biology-department faculty meeting at the University of Alabama in Huntsville on February 2, 2010. Anderson's defense counsel served notice that they intended to argue that Anderson was not guilty by reason of mental disease or defect. The circuit court entered an order granting defense counsel's ex parte motion for extraordinary expenses, but no payment was made in response to the court's order. Finding that Anderson did not show that she satisfied her burden of showing a refusal by the circuit court to enforce its orders, the Supreme Court denied Anderson's petition for the writ of mandamus. View "Alabama v. Anderson" on Justia Law

Bridget Weaver and two other school administrators sued the Board of School Commissioners of Mobile County ("the Board") and Roy D. Nichols, in his official capacity as superintendent of the Mobile County Public School System (collectively, "Defendants") seeking a declaratory judgment, a writ of mandamus, and injunctive relief. Weaver alleged that she had been partially terminated or demoted from her employment as an assistant principal pursuant to a reduction-in-force policy implemented by the defendants; that she was entitled to the benefit of policy no. 6.44, which mandated that "any tenured employee terminated or demoted pursuant to [a reduction-in-force policy] shall have a one-time recall right to a position for which he or she is certified and legally qualified"; and that, since the time of Weaver's partial termination or demotion, several assistant principals with less seniority than her have been placed in available assistant-principal positions. The trial court awarded backpay and ordered that she be offered an assistant-principal position once one became available. Defendants moved the trial court to alter, amend, or vacate its final judgment which was ultimately denied. Defendants appealed. Upon review, the Supreme Court found that Plaintiffs sued the wrong entities: the Board and Superintendent were entitled to immunity from suit with regard to their cases. Accordingly, the Supreme Court concluded that the trial court lacked jurisdiction over Plaintiffs' claims against the board. Because both the Board and Superintendent appealed from void judgments, the Court dismissed their appeals for want of jurisdiction. View "Bd. of School Commissioners of Mobile County v. Weaver" on Justia Law

Clay Slagle appealed the Montgomery Circuit Court's dismissal of his action against the seven members of the Montgomery County Board of Education ("the Board") and the superintendent of the Montgomery County School System alleging that they violated the Alabama Open Meetings Act. The conflict arose from a June 2009 meeting in which the Board was scheduled to discuss and vote on the selection of a new superintendent. There was conflicting evidence as to the nature of the discussion that occurred at the meeting between the Board members who attended it. Slagle testified that, at a meeting of the Board held on July 1, 2009, one Board member made a comment about a previously held "secret meeting" of Board members, apparently referring to the June 2009 event at which four members of the Board were present. None of the Board members present at the June 2009 event confirmed that they deliberated about filling the superintendent position or other Board business at the event. At a July meeting, the Board voted to hire Barbara Thompson as superintendent of the Montgomery School System. In December 2009, Slagle filed this action against Board members Ross, Snowden, Sellers, Meadows, Dawkins, Briers, and Porterfield in their official capacities and against Thompson in her official capacity as superintendent, alleging that the Board members violated the Act in June 2009. The trial court concluded that, because a quorum was not physically present and discussing Board business at any given time at the June event, the Board did not hold a "meeting" as defined in the Act. Based on this finding, the trial court dismissed Slagle's claims against the Board members and Superintendent Thompson. Upon review, the Supreme Court concluded that a plain reading of the Open Meetings Act showed that neither the presence of Board members at the June 2009 event constituted a "gathering" of a quorum of the Board itself. Therefore, the trial court's judgment in this case was affirmed. View "Slagle v. Ross" on Justia Law

Mary Ann Wilkinson was employed by the Board of Dental Examiners of Alabama for several years, until the Board terminated her employment in December 2009. In July 2010, Wilkinson sued the Board, seeking compensation she alleged was due her pursuant to her employment contracts. The Board filed a motion to dismiss Wilkinsons complaint, in which it alleged that the complaint should be dismissed pursuant to Rule 12(b)(1), Ala. R. Civ. P., on the ground that the trial court lacked subject-matter jurisdiction because the Board, as a State agency, is immune from suit under Ala. Const. 1901, Art. I, sec. 14; that the complaint should be dismissed pursuant to Rule 12(b)(6), Ala. R. Civ. P., because it failed to state a claim; and that the complaint should be dismissed pursuant to Rule 12(b)(3), Ala. R. Civ. P., for improper venue. In its petition for a writ of certiorari, the Board argued this case presented an issue of first impression regarding whether the Board is a State agency that is entitled to section 14 immunity and whether the Board was entitled to invoke the jurisdiction of the Board of Adjustment. The Board argues that the Court of Civil Appeals erred when it concluded that the Board was not a State agency entitled immunity. Upon review, the Supreme Court concluded the Board was a State agency and therefore entitled to immunity pursuant to section 14, the courts of this State were without jurisdiction in this case, and the Board of Adjustment would have jurisdiction over Wilkinsons claims. For these reasons, the Court of Civil Appeals erred when it reversed the trial courts judgment dismissing Wilkinsons complaint against the Board and remanded the case for further proceedings. View "Wilkinson v. Board of Dental Examiners of Alabama" on Justia Law

Marcus Lydell Walker, an employee of the Macon County Sheriffs Department, petitioned the Supreme Court for a writ of mandamus to direct the Macon Circuit Court to enter an order holding him immune from suit based on Art. I, sec. 14, Ala. Const. 1901. He further asked the Court to direct the Macon Circuit Court to dismiss the claims asserted against him by Miguel Harris. While acting within the scope of his duty for the Sherriffs Department, Walker and Harris were in a vehicle accident in which Harris was injured. Upon review, the Supreme Court found that Walker demonstrated a clear legal right to the relief he sought. Therefore, the Court granted his petition and directed the circuit court to dismiss the claims asserted against Walker. View "Harris v. Walker" on Justia Law

The Fort Morgan Civic Association, Inc. and Charles Browdy, a resident of the unincorporated Fort Morgan area of Baldwin County and a member of the Association (collectively "the FMCA"), sued the City of Gulf Shores and its mayor and city council seeking a court order declaring the City's annexation of a 19.3-mile segment of the land on which Fort Morgan Road is located and the adjacent land to be invalid.1 Following a nonjury trial, the trial court held that the FMCA had failed to establish that the Fort Morgan annexation was invalid; it accordingly entered a judgment in favor of the City. The FMCA appealed. Upon review, the Supreme Court reversed and remanded: "because the FMCA submitted evidence at that trial indicating that two parcels of property included in the Fort Morgan annexation were owned by private individuals and because the City failed to submit any evidence indicating that those same parcels were owned by the State, the trial court exceeded its discretion in upholding the annexation." View "Fort Morgan Civic Association, Inc. v. City of Gulf Shores" on Justia Law