Justia Alabama Supreme Court Opinion Summaries

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

After suffering personal injuries in a motor-vehicle accident, a plaintiff obtained a default judgment in 2005 against the defendant for $1,500,000. More than a decade later, the plaintiff revived the judgment and secured a writ of garnishment against the defendant’s wages through her employer, a property management company. Wage garnishment payments were made for nearly eight years. In 2024, the employer sold most of its assets to another company, and the defendant’s employment with the original employer ended.Following this, the employer (now renamed) moved to be released from its garnishment obligations, arguing that, since the defendant was no longer employed, it held no further wages subject to garnishment. The motion was signed by the employer’s attorney but did not include a separate affidavit as typically required by statute. The Madison Circuit Court granted the motion the next day, releasing the employer from the garnishment. On that same day, the plaintiff requested the court to set aside the release, citing the lack of affidavit and seeking the right to orally examine the employer under state law. The plaintiff also moved to substitute the successor employer as garnishee. The trial court did not rule on these motions within the required period, so they were deemed denied by operation of law.The Supreme Court of Alabama reviewed the case. The court held that the employer’s amended answer, though lacking a formal affidavit, substantially complied with statutory requirements due to the attorney’s certification. However, the trial court erred by not granting the plaintiff’s timely request to orally examine the employer under the applicable statute. The Supreme Court reversed the trial court’s judgment and instructed it to permit the oral examination as required by law. View "Moore v. Capesius" 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

The case involves a nonprofit religious organization in Shelby County that hosted a wedding reception for two of its missionaries. The organization hired a catering company for the event, and the plaintiff, who operated a catering business, was brought in by another caterer associated with the company to help with the reception. She was paid for her work and arranged for additional staff to assist. At the end of the event, the plaintiff was directed by a member of the organization to exit the building through a specific door. It was dark outside, and there was no exterior lighting in the area. After stepping outside, the plaintiff took a few steps and fell off a loading dock, sustaining serious injuries.The plaintiff sued the organization in the Shelby Circuit Court, alleging negligence, wantonness, and negligent or wanton hiring, training, and supervision. The organization moved for summary judgment, arguing that the plaintiff was a licensee rather than a business invitee and that any danger was open and obvious due to the darkness. The trial court granted summary judgment in favor of the organization. The plaintiff appealed, contesting only the negligence claim.The Supreme Court of Alabama reviewed the case de novo. It determined that the plaintiff was a business invitee because she was present to provide a material benefit to the organization. The court further held that whether the darkness constituted an open and obvious danger was a question of fact for the jury, not an issue to be resolved on summary judgment, because there was evidence the lighting was not total darkness and could have misled a reasonably prudent person. The Supreme Court of Alabama reversed the summary judgment on the negligence claim and remanded the case for further proceedings. View "Joseph v. Caritas of Birmingham" on Justia Law

A mother and father, previously divorced, shared joint custody of their minor son. While visiting his father’s home, the child wandered into a neighbor’s property, accessed a swimming pool, and drowned. Following the child’s death, the mother—on behalf of her son—filed a wrongful death suit against both the father and the neighbor. The father cross-claimed against the neighbor for wrongful death as well. The neighbor settled with both parents, and the settlement funds were interpleaded with the Jefferson Circuit Court, Bessemer Division, which then dismissed all claims against the neighbor.After the neighbor’s dismissal, the mother received half of the settlement funds. The father’s portion was held by the court pending resolution of a related criminal case, in which the father later pleaded guilty to criminally negligent homicide. The mother then requested that the court award her the remainder of the funds, arguing that Alabama law and public policy prohibited the father from benefitting financially from his son’s death. The father argued that because his conviction did not involve a felonious and intentional killing, he was not barred from recovery. The trial court agreed with the father and ordered the remaining funds to be disbursed to him, while reserving all other issues for trial or further hearing.Upon appeal, the Supreme Court of Alabama reviewed the case. The Court held that it lacked jurisdiction because the order appealed from was not a final judgment. The trial court had expressly reserved remaining claims—specifically, the wrongful death claim against the father—so not all issues between all parties had been conclusively resolved. The Supreme Court of Alabama therefore dismissed the appeal. View "B.S.H. v. Humphryes" on Justia Law

The appellant arrived at the emergency room of a medical center with severe lower back pain, right flank pain, and numbness and weakness in her left leg. Initial evaluations suggested symptoms consistent with sciatica, but further testing revealed profound anemia and a herniated disk, which did not warrant surgery. Imaging also showed a nonoccluding thrombus in her aorta. She was discharged after several days, with recommendations for follow-up. About two weeks later, she returned to the hospital with ischemic symptoms in her left leg, which led to an above-the-knee amputation due to advanced ischemia.The matter was initially heard in the Houston Circuit Court, where the appellant sued the medical center and a physician for negligence, alleging that improper evaluation and failure to initiate anticoagulant therapy resulted in limb loss. The physician was dismissed as a defendant, leaving the case against the medical center. After discovery, the medical center moved for summary judgment, arguing the appellant lacked substantial evidence of causation. The circuit court granted summary judgment, finding that causation could not be established.Upon appeal, the Supreme Court of Alabama reviewed the grant of summary judgment de novo, applying the standard that summary judgment is appropriate only when no genuine issue of material fact exists and the moving party is entitled to judgment as a matter of law. The Court found that the appellant failed to present expert testimony establishing a proximate causal connection between the alleged breach and her injury. The medical expert's causation testimony was deemed speculative, as it relied on hypothetical actions by a vascular surgeon outside the expert’s specialty. The medical center’s expert, a vascular surgeon, testified that no different treatment would have been provided. The Supreme Court of Alabama affirmed the circuit court’s judgment. View "Armour v. Southeast Alabama Medical Center" on Justia Law

A woman visited a Huntsville shopping center in May 2021, where renovations were underway, including the installation of new sidewalks in front of a Staples store. The construction zone was marked with barricades, caution tape, signage, and fluorescent paint to warn pedestrians of uneven concrete resulting from recent work. Despite these measures, the woman tripped and fell while walking through the marked area, attributing her fall to a slight elevation change in the concrete. She later filed suit against the property owner, the general contractor, a concrete-cutting subcontractor, and Staples, alleging negligence, wantonness, premises liability, and respondeat superior.The Madison Circuit Court entered summary judgment in favor of the shopping center owner and the general contractor, finding no genuine issue of material fact. The subcontractor was dismissed by agreement, and the plaintiff later settled with Staples’ successor. The circuit court did not specify its reasoning for the decision. After her postjudgment motion failed, the plaintiff appealed.The Supreme Court of Alabama reviewed the summary judgment de novo, considering whether the alleged hazard was open and obvious, which would negate the defendants’ duty to warn or maintain. The court concluded that, as a matter of law, the multiple warnings—including barricades and fluorescent paint—rendered the uneven concrete an open and obvious condition to a reasonable person. Therefore, the defendants owed no additional duty to warn, and the plaintiff’s claims for negligence and wantonness failed as a matter of law. The Supreme Court of Alabama affirmed the judgment of the Madison Circuit Court. View "Walter v. Branch Hays Farm SC Associates, LP" on Justia Law

A homeowner alleged that he hired a roofing company in 2011 to install a specific type of roof on his residence. After installation, problems with roof materials became apparent, including issues with a protective layer that remained unresolved despite multiple repair attempts by both the roofing company and the manufacturer over more than a decade. The homeowner asserted that these defects persisted, and that communication from the roofing company ceased in early 2024. As a result, he filed a lawsuit in Etowah County, Alabama, alleging breach of express and implied warranties, as well as negligent or wanton installation and repair, and sought damages.The roofing company moved to dismiss the lawsuit for improper venue, arguing that a forum-selection clause in a “Service Agreement” required all disputes to be heard in Madison County, Alabama. The company attached an unsigned and undated sample agreement to its motion, but did not produce a copy signed by the homeowner or any evidence that the homeowner had agreed to such a clause. The homeowner responded that he had never signed, nor was he aware of, the agreement submitted by the company and also challenged the clause’s reasonableness. The Etowah Circuit Court denied the company’s motion to dismiss for improper venue.The Supreme Court of Alabama reviewed the company’s petition for a writ of mandamus, which sought to compel the lower court to dismiss the case or transfer it to Madison County. The Supreme Court held that the company failed to meet its burden of proving that the forum-selection clause applied, as it did not present evidence linking the blank agreement to the parties’ actual contract. Therefore, the Supreme Court of Alabama denied the petition, concluding that the circuit court did not clearly err in refusing to dismiss or transfer the case. View "Ex parte Continental Roofing Company, LLC" on Justia Law

A woman underwent cervical spine surgery and subsequently developed neurological symptoms, including balance problems, dizziness, and sensory changes. Her surgeon referred her to a neurologist at a specialty clinic, where she was evaluated by a physician who ordered a brain MRI. The MRI report noted findings that could not exclude multiple sclerosis (MS), but the neurologist did not inform the patient of these results, believing there were no dangerous findings that required immediate notification. The patient was not scheduled for further follow-up and continued to experience worsening symptoms over the next 19 months. Eventually, her primary doctor referred her to another neurologist, who diagnosed her with MS and began treatment, after which her condition stabilized.The patient and her husband filed a medical malpractice suit in Madison Circuit Court, alleging that the neurologist and the clinic negligently failed to inform her of her abnormal MRI results and failed to provide appropriate follow-up, leading to a significant delay in her MS diagnosis and treatment. During discovery, the plaintiffs’ expert testified that the delay worsened her symptoms, but when questioned, he stated he could not say with certainty that an earlier diagnosis would have changed her outcome. The circuit court granted summary judgment for the defendants, finding insufficient evidence of causation, and later struck the expert’s postjudgment affidavit as untimely.On appeal, the Supreme Court of Alabama affirmed the circuit court’s decision to strike the late-filed affidavit but reversed the summary judgment. The Supreme Court concluded that, when viewing the expert’s testimony as a whole and in the light most favorable to the plaintiffs, there was sufficient evidence for a jury to decide whether the neurologist’s failure to inform and follow up probably worsened the patient’s condition. The case was remanded for further proceedings. View "Keister v. Neurology Consultants of Huntsville, P.C." on Justia Law

A woman who had resided at an apartment complex in 2021 was injured when a bullet, fired from outside her apartment, struck her. She filed a pro se complaint with the Montgomery Circuit Court before the expiration of the statute of limitations, seeking to hold the apartment management responsible for her injuries on the basis that tenants were supposed to have 24-hour security due to increasing crime. The complaint, in the form of a letter, did not explicitly name a defendant or assert specific legal claims, but accompanying documents identified Hubbard Properties as the defendant and provided an address for service. However, she did not include summonses or provide instructions regarding service of process.No action was taken in the case until a status conference was held nearly two years later. Several months after that, and after the limitations period had expired, the plaintiff amended her complaint with the assistance of counsel, formally naming both Stonebridge and Hubbard Properties as defendants and asserting claims of negligence, wantonness, and failure to provide safe premises. At that time, she also included summonses and requested service by certified mail, and both defendants were served after the limitations period expired. The defendants moved to dismiss the complaint, arguing that the claims were barred by the statute of limitations because the plaintiff had not made a bona fide attempt to have the original complaint immediately served. The Montgomery Circuit Court denied the motions to dismiss without explanation.The Supreme Court of Alabama granted the defendants' petition for a writ of mandamus. The court held that, although the complaint was filed before the statute of limitations expired, the plaintiff did not have the bona fide intent to have it immediately served, as objectively required for timely commencement of an action under Alabama law. Because of this, and because service occurred after the limitations period, the court directed the circuit court to dismiss the complaint with prejudice. View "Ex parte Stonebridge, LLC" on Justia Law