Justia Alabama Supreme Court Opinion Summaries

Lonas Goins was injured when a train locomotive that he was operating collided with a garbage truck at a railroad intersection. Goins sued the owner and the driver of the truck. After a five-day trial, a jury found in favor of Goins and awarded him damages. Dissatisfied with the jury's damages award, Goins appealed the judgment, arguing that the trial court committed multiple errors that warranted a new trial. Finding no reversible error, the Alabama Supreme Court rejected Goins's arguments and affirmed the judgment. View "Goins v. Advanced Disposal Services Gulf Coast, LLC" on Justia Law

Chris and Suzanne Moore, as parents and next friends of Sydney Moore, a minor, appealed the grant of summary judgment entered in favor of Pamela Tyson and Jennifer Douthit, two employees of the Huntsville City Board of Education ("the Board"), with regard to negligence and wantonness claims asserted against Tyson and Douthit by the Moores arising from injuries suffered by Sydney at her elementary school. Tyson was employed by the Board as a teacher at Goldsmith-Schiffman Elementary School. Douthit was employed as the principal of the school. Sydney was enrolled at the school as a third-grade student in Tyson's class. Tyson left the students unsupervised in the classroom while she went to the restroom. During that time, Sydney and another student in the class left their seats, and, according to Sydney, the other student caused her to fall and hit her head and face on a counter in the classroom. Sydney suffered injuries from her fall, including fractures of her left orbital bone, her eye socket, and her nose and entrapment of her eye. Sydney was admitted for treatment at a hospital and underwent surgery as a result of the injuries. THe Alabama Supreme Court determined the Moores did not demonstrate the trial court erred in entering summary judgment in favor of Tyson and Douthit based on immunity. Accordingly, the Court affirmed the trial court's judgment. View "Moore v. Tyson" on Justia Law

Defendant Allstate Property and Casualty Insurance Company ("Allstate"), appealed a circuit court's order granting the posttrial motion of the plaintiff, Doyle Harbin, which sought the imposition of sanctions based on Allstate's purported violation of a pretrial mediation order. In 2015, Harbin was injured as the result of a motor-vehicle accident that he alleged was caused by Irvin Stewart. Harbin subsequently filed a complaint in the trial court asserting a negligence claim against Stewart. In the same complaint, Harbin also named Allstate, Harbin's automobile insurance carrier, as a defendant and sought to recover uninsured/underinsured-motorist ("UIM") benefits under his Allstate policy. Following Stewart's dismissal, Harbin, without opposition from Allstate, requested that the scheduled trial date be continued and the matter referred to mediation. Unable to reach a settlement, the matter proceeded to trial. A jury returned a $690,000 verdict in Harbin's favor. Approximately two weeks later, Harbin filed a "Motion for Entry of Judgment and Motion for Sanctions," essentially contending Allstate in bad faith failed to abide by the Order which set the Court-ordered mediation in which Allstate had agreed to participate. The motion requested Allstate pay Harbin's trial-related attorneys' fees. The Alabama Supreme Court found the evidence failed to show Allstate violated the trial court's mediation order, thus it exceeded its discretion by issuing Harbin's requested sanctions. The Court therefore reversed the portion of the trial court's order imposing sanctions exceeding Harbin's request for costs and fees totaling $57,516.36, and remanded this matter for further proceedings. View "Allstate Property & Casualty Ins. Co. v. Harbin" on Justia Law

Allstate Insurance Company ("Allstate") and its insured, Kaitlin Ogletree, disagreed about the extent of damages incurred in an automobile accident that Ogletree had with an underinsured motorist. During closing arguments, Ogletree's counsel made inaccurate statements unsupported by the evidence presented at trial. The jury returned a verdict for Ogletree, and Allstate appealed on account of the allegedly improper closing argument. The Alabama Supreme Court concluded the incorrect statements were prejudicial and adequate grounds for a new trial. Allstate's objection to the argument was properly preserved, and the Court found those statement were not provoked by an improper statement from Allstate's counsel. Judgment was reversed and the matter remanded for a new trial. View "Allstate Insurance Co. v. Ogletree" on Justia Law

Randall Pruitt appealed the grant of summary judgment against him and in favor of James Oliver with respect to Pruitt’s claims of negligence and wantonness stemming from a collision between Oliver’s car and Pruitt’s wheelchair. At the time of the accident, Pruitt’s wheelchair was equipped with a seat belt, two six-beam flashlights on the footrest, two flashing red bicycle lights on the back of his arm rests, some red reflectors on the back, and an orange vest with reflective yellow tape draped over the back. The maximum speed of the motorized wheelchair was five miles per hour. On a “pretty” night in April 2013, Pruitt was dropped off from the bus; his apartment was located across a four-lane road across from the bus stop. According to a witness, Oliver appeared to be trying to “beat a yellow light. He made the turn at a high rate of speed and hit the electric wheelchair from behind. The man in the chair was launched out of his seat and landed in the roadway. I could tell the chair had significant damage.” Oliver contended at trial Pruitt’s wheelchair was a “motor vehicle” under Alabama’s motor-vehicle and traffic code, and because the chair lacked certain safety equipment, Pruitt was “contributorily negligent per se” and should have been barred from recovering on his negligence claim. In the alternative, Oliver contended Pruitt, as a pedestrian, violated the rules for crossing a street where there was no crosswalk because he failed to yield the right-of-way to Oliver’s car, and failed to walk “as near as practicable to the outside edge of the roadway.” The Alabama Supreme Court concluded motorized wheelchairs were indeed “motor vehicles” under the pertinent provision of Alabama’s motor-vehicle and traffic code, but an issue of fact existed as to whether Pruitt’s violation of safety-feature-requirements for motor vehicles was the proximate cause of the accident. Furthermore, the Court concluded the trial court erred in finding there was not substantial evidence of Oliver’s alleged subsequent negligence, and therefore, that issue had to be submitted to a jury. Summary judgment in favor of Oliver with respect to Pruitt’s wantonness claim was affirmed. View "Pruitt v. Oliver" on Justia Law

James Olvey was killed when his vehicle was struck head on by a vehicle driven by Donald Wright II, who was driving the wrong way on Interstate 65 ("I-65") while attempting to flee the police. James Griffin, the personal representative of Olvey's estate, sued Wright, the City of Trafford ("Trafford"), the City of Warrior ("Warrior"), and other named and fictitiously named parties, alleging that they shared responsibility for Olvey's death. Over a year later, Griffin amended his complaint to substitute Trafford police officer Dylan McCoy and Warrior police officers Stephen Scott and James Henderson ("the defendant officers") for fictitiously named defendants. The defendant officers moved to enter a judgment in their favor, arguing that the amended complaint was untimely and thus barred by the applicable statute of limitations. The trial court denied their motion, and the defendant officers petitioned the Alabama Supreme Court for mandamus relief. After review of the trial court record, the Supreme Court determined Griffin had ample opportunity to discover the identities of the defendant officers before filing suit - and did not follow through. Therefore, he was not able to avoid the bar of the statute of limitations, and the defendant officers were entitled to the writ of mandamus. View "Ex parte McCoy, Scott, and Henderson." on Justia Law

Anthony Nix, a police officer for the City of Haleyville ("the City"), and the City appealed a judgment entered on a jury verdict in favor of John Myers. Myers filed suit asserting claims of negligence, wantonness, and negligence per se against Officer Nix and, based on the doctrine of respondeat superior, the City. Myers also asserted that the City had negligently and/or wantonly hired, trained, and supervised Officer Nix. The Alabama Supreme Court determined the trial court reversibly erred by providing the trial court to provide to the jury a copy of the statutes upon which the jury had been charged. Accordingly, Officer Nix and the City were entitled to a reversal of the judgment and a new trial. View "Nix v. Myers" on Justia Law

Harbor Freight Tools USA, Inc. ("Harbor Freight"), petitioned the Alabama Supreme Court for a writ of mandamus to direct the Lowndes Circuit Court to vacate its order granting a motion to compel discovery in an action Thomas and Juanita Webster ("the Websters") brought against Harbor Freight and others and to enter a protective order involving the requested discovery. The Websters previously hired Randall "Bubba" Wills and Jason Little to construct and install an elevator system in their house. In November 2016, Wills repaired the elevator system. To complete the repairs, Wills purchased from Harbor Freight a "Haul Master" 4,000-pound lifting block. According to Harbor Freight, its instruction manual for the lifting block expressly stated that the lifting block should not be used to transport people in an elevator system. Despite a posted warning, Wills tested the elevator system and rode in the elevator basket with Thomas Webster after Wills had installed the lifting block and completed the repairs. In December 2016, the Websters, along with their son Robbie, were riding in the elevator basket when it fell. To the extent that Harbor Freight sought mandamus relief on the grounds that the trial court's July 16, 2020, order granting the Websters' motion to compel failed to limit discovery, the Supreme Court determined the petition for mandamus relief was premature because Harbor Freight failed to seek a protective order raising the need for those limitations on discovery after the trial court entered the order granting the Websters' motion to compel. To the extent that Harbor Freight sought mandamus relief based on the trial court's implicit denial of its motion to adopt its proposed protective order, the Court determined Harbor Freight failed to demonstrate that any information that might be disclosed by providing the requested documents warrants the protections outlined in the proposed protective order. Accordingly, Harbor Freight's petition was denied. View "Ex parte Harbor Freight Tools USA, Inc." on Justia Law

Michael Brown petitioned the Alabama Supreme Court for a writ of mandamus to direct the Lee Circuit Court to dismiss, pursuant to Rule 12(b)(6), Ala. R. Civ. P., the complaint filed against him by Christopher Beamon. Brown claimed the complaint should have been dismissed on the basis that the claims asserted in the complaint were barred by the applicable statute of limitations and that the doctrine of equitable tolling was inapplicable to suspend the running of the limitations period. IN 2017, pedestrian Beamon was injured when he was struck by a vehicle driven by Brown; the accident occurred in Auburn. In 2019, Beamon filed a complaint in the United States District Court for the Middle District of Alabama, naming as defendants Brown and Geico Casualty Company. In that complaint, Beamon asserted state-law claims and purported to invoke the federal court's diversity jurisdiction. Despite alleging diversity jurisdiction, the complaint stated that both Beamon and Brown were citizens of Alabama. Brown answered the complaint, asserting as a defense lack of subject-matter jurisdiction. In his motion to dismiss, Brown asserted the federal court lacked subject-matter jurisdiction over the complaint because complete diversity of citizenship was lacking between him an Beamon. Beamon moved to amend his complaint, asserting Brown was a citizen of Georgia, or alternatively, if the evidence was insufficient to support diversity jurisdiction, the court allow equitable tolling of the statute of limitations, which would allow him to refile his claims in a state court. On November 22, 2019, while the federal case was pending, but after the two-year limitations period had run, Beamon filed a second complaint, this time in the Lee Circuit Court, asserting the same claims against Brown as he had asserted in the federal court. The federal court dismissed the complaint without prejudice. The Alabama Supreme Court determined Brown did not establish a clear legal right to dismissal of the complaint filed at circuit court. "This case does not come within the exception to the general rule that a petition for the writ of mandamus is not the appropriate means by which to seek review of the merits of an order denying a motion to dismiss." View "Ex parte Michael Brown." on Justia Law

The Health Care Authority for Baptist Health, an affiliate of UAB Health System ("HCA"), and The Health Care Authority for Baptist Health, an affiliate of UAB Health System d/b/a Prattville Baptist Hospital (collectively, "the HCA entities"), appealed a circuit court order denying their motion to compel arbitration in an action brought by Leonidas Dickson, II. In 2015, Dickson sustained injuries as a result of an automobile accident. Following the accident, Dickson was taken to Prattville Baptist Hospital ("PBH"), where he was treated and discharged. Dickson was partially covered by a health-insurance policy issued by Blue Cross and Blue Shield of Alabama, Inc. ("BCBS"). PBH was a party to a "Preferred Outpatient Facility Contract" ("the provider agreement") with BCBS, under which the medical care rendered to Dickson in the emergency department at PBH was reimbursable. In 2017, Dickson filed a complaint to challenge a reimbursement that PBH had received in exchange for Dickson's medical treatment. Dickson's complaint also sought to certify a class of people who were insured by BCBS and who had received care at any hospital operated by HCA's predecessor, Baptist Health, Inc. ("BHI"). After the HCA entities' motion to dismiss was denied, the HCA entities filed an answer to the lawsuit, but the answer did not raise arbitration as a defense. After a year of extensive discovery (including class certification and class-related discovery), the HCA entities moved to compel arbitration on grounds that Dickson's health-insurance policy with BCBS required all claims related to the policy to be arbitrated and that the provider agreement also provided for arbitration, contingent upon the arbitration requirements of the BCBS policy. The trial court denied the motion to compel without providing a reason for the denial. After a request for reconsideration was also denied, the HCA entities appealed. The Alabama Supreme Court concluded the HCA entities waived their right to arbitration, thus affirming the trial court order. View "The Health Care Authority for Baptist Health v. Dickson" on Justia Law