Justia Alabama Supreme Court Opinion Summaries

In 2010, Crystal Kaye Coan purchased a property in Lauderdale County, which was subject to a mortgage. Coan defaulted on the mortgage, leading to a foreclosure by Carrington Mortgage Services, LLC, the mortgage assignee. Carrington sold the property to Championship Property, LLC in an online auction in May 2018. Championship then filed an ejectment action against Coan, claiming it was the title owner and seeking possession of the property. Coan countered that the foreclosure sale was void, and therefore, Championship had not acquired the title. In January 2023, Championship requested the trial court to require Coan to deposit $2,000 per month with the court clerk pending a final ruling in the ejectment action. The trial court, over Coan's objection, ordered her to deposit $800 per month.Coan failed to deposit the court-ordered payments for March, April, and May 2023, leading Championship to move the trial court to hold her in contempt. The trial court found Coan in contempt and, as a sanction, ruled in favor of Championship on its ejectment claim, awarding it possession of the property. Coan appealed this decision.The Supreme Court of Alabama affirmed the trial court's decision to require Coan to deposit $800 per month with the court clerk, stating that the trial court had the authority to enter the escrow order. The court also affirmed the trial court's finding of contempt against Coan for failing to comply with the escrow order. However, the court reversed the trial court's sanction awarding Championship possession of the property, stating that the sanction was not appropriate given the current posture of the litigation. The case was remanded to the trial court for further proceedings consistent with the Supreme Court's opinion. View "Coan v. Championship Property, LLC" on Justia Law

Harold Wallace, a tenant of the Housing Authority of the City of Talladega, fell while descending the back-porch stairs of his apartment due to missing handrails. Wallace sued the Housing Authority for negligence and wantonness. The Housing Authority moved for a summary judgment, arguing that the lack of handrails was an "open and obvious" danger and that Wallace had conceded in his deposition that he was aware of this. The trial court granted the Housing Authority's motion for a summary judgment. Wallace appealed to the Court of Civil Appeals.The Court of Civil Appeals reversed the trial court's summary judgment in favor of the Housing Authority. The Housing Authority then petitioned the Supreme Court of Alabama for certiorari review, arguing that the Court of Civil Appeals' decision conflicts with a prior decision in Daniels v. Wiley, where the court affirmed a summary judgment for the defendant landlord after concluding that the landlord had no duty to the plaintiff tenant with respect to risks created by the muddy condition of a sidewalk within her apartment complex because the danger was "open and obvious."The Supreme Court of Alabama affirmed the decision of the Court of Civil Appeals, concluding that the decision does not conflict with Daniels. The court clarified that while the Daniels decision is sound, it should not be interpreted as rejecting a landlord's duties under the circumstances described in §§ 360 and 361 of the First Restatement and the Second Restatement. The court found that the Housing Authority failed to raise a genuine issue of material fact as to whether the principles set forth in §§ 360 and 361 apply to the circumstances in this case, and therefore, the Housing Authority was not entitled to a judgment as a matter of law. View "Ex parte The Housing Authority of the City of Talladega" on Justia Law

Seneathia K. Porter initiated an unlawful-detainer action against Tracy Murray, doing business as Tracy's Treasure Company, LLC ("Murray"), seeking possession of commercial property and the recovery of, among other things, unpaid rent, late fees, insurance costs, taxes, and attorney's fees. Porter claimed she owned the property, she had leased the property to Murray on a month-to-month basis for the sum of $1,500 per month, Murray defaulted under the lease by failing to pay rent in accordance with the lease, and that she had provided Murray with written notice that her right of possession of the property had been terminated. Murray, on the other hand, denied that she had leased the property. Rather, she claimed she had executed a contract to purchase the property and had made improvements to the property. Following a bench trial, the circuit court purported to enter a judgment in favor of Porter and against Murray. Murray appealed. The Alabama Supreme Court dismissed the appeal, finding no evidence that the district court had adjudicated the unlawful-detainer action. Thus, the circuit court lacked jurisdiction over the action and the judgment it entered was void and, therefore, would not support an appeal. View "Murray v. Porter" on Justia Law

This appeal and cross-appeal involved a residential lease agreement with an option to purchase executed by Tony Hiett, Sr., and his wife Kelly Hiett ("the tenants") and Beverlye Brady ("the landlord"). According to the tenants, they accepted the first option to purchase the property presented in the landlord's email and began making monthly holdover rental payments of $2,500. And, in April 2017, they informed the landlord that they had obtained financing and were ready to close on the property by April 30, 2017. The landlord, however, refused to convey title to the property because, she claimed, the tenants had never responded to her email; thus, according to the landlord, the option to purchase had expired. The tenants thereafter stopped paying rent under the lease agreement, but continued to occupy the property, and sued the landlord, seeking specific performance of the option to purchase. The landlord counterclaimed, asserting a claim for ejectment and a claim of breach of contract, based on unpaid rent and late fees owed under the lease agreement. The Alabama Supreme Court affirmed the judgment entered on the jury's verdict in favor of the tenants on their specific-performance claim and against the landlord on her ejectment claim. The Supreme Court reversed the judgment entered on the jury's verdict in favor of the landlord on her breach-of-contract claim based on the inadequacy of damages awarded, and the Court remanded the case with directions to the trial court to grant a new trial as to only that claim, unless the tenants consented to an additur. View "Hiett v. Brady" on Justia Law

This appeal and cross-appeal involved a residential lease agreement with an option to purchase executed by Tony Hiett, Sr., and his wife Kelly ("the tenants") and Beverlye Brady ("the landlord"). The landlord leased to the tenants a house ("the property") located in Auburn for a term of five years, beginning September 1, 2011, and ending August 31, 2016, for $2,000 per month. By letter dated August 29, 2016, the tenants informed the landlord that they were exercising their option to purchase the property. According to the tenants, they accepted the first option to purchase the property presented in an email from the landlord and began making monthly holdover rental payments of $2,500. In April 2017, they informed the landlord that they had obtained financing and were ready to close on the property by April 30, 2017. The landlord, however, refused to convey title to the property because, she claimed, the tenants had never responded to her email; thus, according to the landlord, the option to purchase had expired. The tenants thereafter stopped paying rent under the lease agreement, but continued to occupy the property, and sued the landlord, seeking specific performance of the option to purchase. The landlord counterclaimed, asserting a claim for ejectment and a claim of breach of contract, based on unpaid rent and late fees owed under the lease agreement. The Alabama Supreme Court affirmed judgment on a jury’s verdict in favor of the tenants on their specific performance claim, and against the landlord on her ejectment claim. The Supreme Court reversed judgment entered on the jury’s verdict in favor of the landlord on her breach-of-contract claim based on the inadequacy of damages awarded, and the Court remanded the case with directions to the trial court to grant a new trial only as to that claim unless the tenants consented to an additur. View "Brady v. Hiett" on Justia Law

As a matter of first impression, the Alabama Supreme Court addressed whether Rule 55(b)(2), Ala. R. Civ. P., required a trial court to hold a hearing before entering a default judgment. The Court of Civil Appeals, in Living By Faith Christian Church v. Young Men's Christian Ass'n of Birmingham, [Ms. 2180674, Mar. 20, 2020] ___ So. 3d ___ (Ala. Civ. App. 2020), determined that the trial court did not err in granting the application for a default judgment filed by the Young Men's Christian Association of Birmingham ("the YMCA") without first holding a hearing. After review, the Supreme Court agreed with the Court of Civil Appeals' determination and concluded that Rule 55(b)(2) did not require a trial court to hold a hearing on every application or motion for a default judgment. View "Ex parte Living By Faith Christian Church" on Justia Law

Paradigm Investment Group, LLC, and HR IV, LLC ("the tenants"), entered into a written lease agreement, which was ultimately assigned to Dewey Brazelton ("the landlord"). The lease obligated the tenants to make rental payments to the landlord from the operation of a fast-food franchise on the leased premises. When the tenants failed to remit rental payments, the landlord sued the tenants for breach of contract and unjust enrichment. The trial court entered a summary judgment in favor of the landlord, finding that the tenants had breached the lease agreement and were obligated to pay the landlord $113,869.44. The tenants appealed, arguing the trial court erred in entering summary judgment in favor of the landlord because they abandoned the leased premises; the lease agreement does not address abandonment; and, therefore, as a matter of law, common-law principles of abandonment, rather than the terms of lease, govern the landlord's available remedies. The tenants assert that, had the trial court correctly applied common-law principles of abandonment, it would not have awarded contract damages under the lease. Finding summary judgment was properly granted in favor of the landlord, the Alabama Supreme Court affirmed. View "Paradigm Investment Group, LLC and HR IV, LLC v. Brazelton" on Justia Law

Woodruff Brokerage Company, Inc., the remaining defendant in this case, appealed the trial court's denial of its motion to set aside the default judgment entered in favor of plaintiff Patricia Beatty. Beatty sued "Woodruff Brokerage Company d/b/a The River and formerly d/b/a Crest Club Apartments," Ricky Dabbs, "Century 21," and fictitiously named defendants. She lived in Crest Club Apartments, and alleged fatigue, nausea, and weakness were cause from prolonged exposure to carbon monoxide from a leaking natural-gas line beneath her bedroom, and that she had been permanently injured as a result of that exposure. Beatty asserted that Woodruff Brokerage had negligently and/or wantonly failed to maintain the premises at Crest Club Apartments in a safe condition. Woodruff defended on faulty service; the Alabama Supreme Court determined there was no properly named addressee on the certified mail allegedly sent to Woodruff, and thus, Beatty failed to prove that the complaint and summons was delivered to "the named addressee" or to the "addressee's agent." Because Beatty's service by certified mail was ineffective, the trial court did not obtain personal jurisdiction over Woodruff Brokerage, and the default judgment against it was void. Therefore, the trial court erred when it denied Woodruff Brokerage's motion to set aside the default judgment. View "Woodruff Brokerage Company, Inc. v. Beatty" on Justia Law

Since November 2012, LNM1, LLC, operated a gasoline station and convenience store in Greensboro, Alabama under a lease agreement with the owner of the property, TP Properties, LLC. In August 2017, TP Properties sued LNM1 and its owner Mohamed Alsahqani seeking to terminate the lease because LNM1 had not maintained all the required insurance coverages. The trial court entered a summary judgment in favor of TP Properties, holding that LNM1's failure to maintain the insurance required by the lease agreement constituted a material breach of that agreement, thus entitling TP Properties to terminate the lease. Finding no reversible error in that judgment, the Alabama Supreme Court affirmed the trial court. View "LNM1, LLC, and Mohamed Alsahqani v. TP Properties, LLC" on Justia Law

Magic City Capital, LLC ("Magic City"), appealed the grant of summary judgment entered by the Madison Circuit Court in favor of Twickenham Place Partners, LLC ("Twickenham"). Because the Alabama Supreme Court determined events that occurred during the trial-court proceedings rendered the action moot and the trial court, therefore, was divested of subject-matter jurisdiction, the Supreme Court dismissed the appeal. View "Magic City Capital, LLC v. Twickenham Place Partners, LLC" on Justia Law