Justia Alabama Supreme Court Opinion SummariesArticles Posted in Juvenile Law
Smith v. Alexander, et al.
Steven Smith, as conservator of the estate of B.J. (minor), appealed a circuit court's grant of summary judgment in favor of defendants Elizabeth Alexander, Amanda Buchanan, and Michael Key on Smith's claims alleging violations of policies promulgated by the State Department of Human Resources ("the State DHR"), negligence, wantonness, and the tort of outrage. In May 2015, Key was employed by the Cullman County DHR as a foster-care supervisor, responsible for supervising Cullman County DHR caseworkers. Key reported to Buchanan, who oversaw the Child Family Services Program, the Child Protective Services Program, and the Foster Care Program for the Cullman County DHR. Buchanan in turn reported to Alexander, the director of the Cullman County DHR. B.J. was placed in the custody of the Cullman County DHR when he was three years old after having suffered physical abuse, sexual abuse, and neglect at the hands of family members. In 2002, the trial court awarded the Cullman County DHR legal guardianship and permanent custody of B.J. While in the custody of the Cullman County DHR, B.J. was placed in a number of foster homes, group homes, residential facilities, hospitals, and psychiatric institutions. In July 2014, B.J. was placed by the Cullman County DHR at the Altapointe Group Home. While there, B.J. underwent an assessment, which revealed he had regularly exhibited violent outbursts and physically aggressive behavior toward others; he had a history of depression, suicide and delusional thinking; and engaged in impulsive and delinquent behavior. B.J. would ultimately be arrested for such behavior towards others. B.J. had personal funds with which he could post bail, but the decision was made he should have remained in jail pending an arrangement for further mental health counseling. Smith argued defendants' decisions leaving B.J. incarcerated did not follow departmental policies of least-restrictive-placement-possible, and as such, caused B.J. irreparable harm. The Alabama Supreme Court found that each crucial decision made by the defendants -- i.e., the decisions not to place B.J. at the Gateway facility and not to post B.J.'s bond before his court date -- were made with B.J.'s best interests in mind after consideration of all the relevant recommendations and factors. Accordingly, Smith failed to provide substantial evidence demonstrating that the defendants acted willfully in dealing with B.J. and that, therefore, they were not entitled to the protection of State-agent immunity. View "Smith v. Alexander, et al." on Justia Law
Ex parte Jimmy Williams, Jr.
The United States Supreme Court vacated the Alabama Supreme Court's earlier judgment in Ex parte Williams, 183 So. 3d 220 (Ala. 2015). Jimmy Williams, Jr., was convicted of murder made capital because it was committed during a robbery in the first degree; the offense was committed when Williams was 15 years old. The trial court sentenced Williams to life imprisonment without the possibility of parole, the only possible sentence and one that was mandatory. In June 2013, Williams petitioned the Montgomery Circuit Court for a new sentencing hearing, asserting that his life-without-the possibility-of-parole sentence was unconstitutional and unlawful in light of Miller v. Alabama, 132 S.Ct. 2455 (2012). The circuit court, the Court of Criminal Appeals, and this Court disagreed, each holding that Williams was not entitled to a new sentencing hearing because the rule in Miller did not apply retroactively to cases such as Williams's, which were final when Miller was decided. Williams petitioned the United States Supreme Court for certiorari review. While Williams's petition for certiorari review was pending, the United States Supreme Court issued its opinion in Montgomery v. Louisiana, 136 S.Ct. 718 (2016)., which clarified its holding in Miller, stating that "Miller announced a substantive rule that is retroactive in cases on collateral review." The Alabama Court vacated the judgment of the Court of Criminal Appeals and remanded this case directly to the circuit court for proceedings consistent with Miller and Montgomery. View "Ex parte Jimmy Williams, Jr." on Justia Law
Ex parte Jimmy Williams, Jr.
In August 2000, when Jimmy Williams, Jr. was 15 years old, he was convicted of murder made capital because it was committed during a robbery. In accordance with the applicable law at the time of Williams's sentencing, the trial court sentenced Williams to life imprisonment without the possibility of parole, the only possible sentence and one that was mandatory. The Court of Criminal Appeals affirmed Williams's conviction and sentence. In June 2013, Williams petitioned the circuit court, asserting that under the rule announced by the United States Supreme Court in "Miller v. Alabama," (132 S.Ct. 2455 (2012)), the mandatory sentence of life imprisonment without the possibility of parole to which he was sentenced in 2000 for an offense committed when he was 15 years old was unconstitutional and, consequently, that he was entitled to be resentenced based on the individualized sentencing factors discussed in Miller. The issue in this case presented for the Alabama Supreme Court's review was whether "Miller" applied retroactively to Williams' case. Because Miller did not categorically forbid a sentence of life imprisonment without parole for a juvenile defendant and because Miller did not apply retroactively, Williams's sentence of life imprisonment without the possibility of parole was legal. The Alabama Supreme Court concluded the Court of Criminal Appeals did not err in denying Williams the relief he requested. View "Ex parte Jimmy Williams, Jr." on Justia Law
G. M. v. Alabama
The State sought certiorari for review of a decision of the Court of Criminal Appeals that reversed the Juvenile Court's decision to deny G.M.'s motion to suppress evidence that G.M. argued was obtained pursuant to an illegal search. The matter was one of first impression for the Supreme Court: whether evidence of a public-school student's association with an individual known to be involved in criminal activity and suspected of being affiliated with a gang, without more, constituted reasonable grounds for a search of the student by a school official under the Fourth Amendment. The Supreme Court concluded that it did not. Therefore, the Court affirmed the Court of Criminal Appeals' judgment. View "G. M. v. Alabama " on Justia Law
Colbert Cty. Bd. of Edu. v. James
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
Hood v. McElroy
Defendant Jo Ann Hood appealed a trial court's order that granted a motion for a new trial filed by Plaintiff Elizabeth McElroy as personal representative of the estate of Austin Taylor Terry (the estate). The mother of Austin Taylor Terry, who was then 12 months old, admitted him to the Children's Hospital of Alabama. A social worker at the hospital notified the county Department of Human Resources (DHR) that Terry had suffered "suspicious non-accidental injuries." Terry's father, who was divorced from Terry's mother, also contacted DHR after he learned of his son's hospitalization. He spoke with an after-hours on-call DHR service worker learned that Chris Wesson, the mother's boyfriend, had been in the house with Terry. The service worker recommended that Terry not be allowed to return home when he was discharged. A DHR supervisor who had not seen the report, assigned Defendant to investigate Terry's suspected abuse and informed the Hospital that Terry could go home with his mother when he was discharged. Based on her investigation, Defendant determined that it was safe to leave Terry in his mother's care. Subsequently, Terry died from brain injuries caused by Wesson. Terry's parents filed separate wrongful-death actions naming Wesson, Children's Hospital, Hood, and other DHR social workers as defendants. The jury returned a verdict in favor of the estate and awarded $25,000 in damages against Wesson and Hood. The estate filed a motion for a new trial, arguing among other things, that a juror's failure to respond to a voir dire question prevented the estate from using its jury strikes effectively because it would have used one to remove the juror had the juror answered the question. After Hood filed her opposition to the estate's postjudgment motion, the court granted the motion on the ground that the estate was probably prejudiced in its right to a fair and impartial trial as a result of the juror's failure to respond to the voir dire question. Upon review, the Supreme Court could not conclude that "[the juror's] failure to reveal, in response to the particular questions asked, [provided] adequate support for a finding ... so as to warrant retrying this case." The Court reversed the trial court and remanded the case for further proceedings. View "Hood v. McElroy" on Justia Law