Justia Alabama Supreme Court Opinion Summaries

Cavalier Manufacturing, Inc. appealed a circuit court order that denied its motion to alter, amend, or vacate an arbitration award entered in favor of Janie Gant. Gant purchased a mobile home manufactured by Cavalier from Demopolis Home Center, L.L.C. ("DHC"). At the time of purchase, Gant and representatives of Cavalier and DHC executed an alternative-dispute-resolution agreement in which they agreed to arbitrate any disputes that might arise among them stemming from Gant's purchase of the mobile home. The mobile home was also covered by a manufacturer's warranty issued by Cavalier that likewise contained a provision requiring arbitration of any disputes that might arise between her and Cavalier relating to the mobile home. Gant was not satisfied with the manner in which DHC delivered and installed the mobile home on her property. Eventually Gant sued, and the matter was submitted to arbitration. The arbitrator awarded Gant $45,550 on her breach-of-express-warranty claim, plus an additional sum to be determined for attorney fees. Cavalier argued on appeal that the trial court erred by confirming the arbitration award in favor of Gant. Finding no error, the Supreme Court affirmed. View "Cavalier Manufacturing, Inc. v. Gant " on Justia Law

John and Judith Valloze and Nationwide Mutual Insurance Company; State Farm Mutual Auto Insurance Company; Freightliner Custom Chassis Corporation; Freightliner, Allison Transmission, Inc. ("Allison Transmission"); and Cummins Atlantic, LLC, separately petitioned the Supreme Court for writs of mandamus to direct the Franklin Circuit Court to dismiss the declaratory-judgment actions filed against them by Tiffin Motor Homes, Inc. Tiffin manufactured and sold custom-made motor homes. In its complaint in the Valloze action, Tiffin alleged that the Vallozes, who reside in Florida, purchased a Tiffin "Allegro Red" motor home that was manufactured by Tiffin in Red Bay, Florida. In 2011, the Vallozes' motor home caught fire somewhere in South Carolina and was declared a total loss. Nationwide insured the motor home, and it paid the Vallozes for their loss. Tiffin subsequently filed a complaint against the Vallozes, Nationwide, Freightliner, Allison Transmission, and Cummins in Alabama, describing Allison Transmission and Cummins as manufacturers of component parts for Tiffin that Tiffin alleged were the source of the fire. The Vallozes, Nationwide, Allison Transmission, Freightliner and Cummins filed motions to dismiss which were ultimately denied. The trial court did not provide reasons for its rulings. All parties appealed. In the Katnich action, Tiffin alleged that Karen Katnich purchased a Tiffin "Phaeton" motor home in Virginia, and somewhere in North Carolina, the motor home caught fire and suffered a total loss. Tiffin sued State Farm, Custom Automated Services, Inc., Waterway, Inc., Maxzone Auto Parts Corporation and Freightliner, alleging each manufactured parts for Tiffin that were the source of the fire. In both cases, Tiffin asserted that a real, present justiciable controversy existed between the parties as to the cause and origins of the motor home fires. Again the trial court denied motions to dismiss, and provided no reasons for its ruling. After its review, the Alabama Supreme Court concluded with the conclusion of the overwhelming majority of other jurisdictions that declaratory-judgment actions were not intended to be a vehicle for potential tort defendants to obtain a declaration of nonliability. Because a bona fide justiciable controversy did not exist either action, the Court concluded that the trial court erred in denying the petitioners' motions to dismiss Tiffin's complaints. View "Tiffin Motor Homes, Inc. v. Valloze " on Justia Law

Rebecca B. McDonald, as administrator of the estate of her son Jeremy Wayne McDonald, sued Kubota Manufacturing of America Corporation, Kubota Corporation, and Kubota Tractor Corporation, asserting various claims after her son died as a result of injuries sustained when a Kubota lawnmower he was operating rolled over, pinning him underneath it. Following a three-week trial, the jury returned a verdict in favor of the Kubota defendants, and the trial court entered a judgment on that verdict. McDonald's subsequent motion for a new trial was denied by the trial court, and McDonald appealed to the Supreme Court, arguing that she was entitled to a new trial based on juror misconduct and errors the trial court made when instructing the jury. Finding no abuse of discretion nor errors at trial, the Supreme Court affirmed. View "McDonald v. Kubota Manufacturing of America Corporation et al. " on Justia Law

The United States District Court for the Middle District of Alabama, Southern Division certified a question to the Alabama Supreme Court: "Under Alabama law, may a drug company be held liable for fraud or misrepresentation (by misstatement or omission), based on statements it made in connection with the manufacture or distribution of a brand-name drug, by a plaintiff claiming physical injury from a generic drug manufactured and distributed by a different company?" Plaintiffs Danny and Vicki Weeks filed this action against five current and former drug manufacturers for injuries that Mr. Weeks allegedly suffered as a result of his long-term use of the prescription drug product metoclopramide, the generic form of the brand-name drug "Reglan." The Weekses contended that the Wyeth defendants had a duty to warn Danny's physician about the risks associated with the long-term use of metoclopramide and that the Weekses, as third parties, have a right to enforce the alleged breach of that duty. The Supreme Court concluded: "[i]n the context of inadequate warnings by the brand-name manufacturer placed on a prescription drug manufactured by a generic-drug manufacturer, it is not fundamentally unfair to hold the brand-name manufacturer liable for warnings on a product it did not produce because the manufacturing process is irrelevant to misrepresentation theories based, not on manufacturing defects in the product itself, but on information and warning deficiencies, when those alleged misrepresentations were drafted by the brand-name manufacturer and merely repeated by the generic manufacturer." View "Wyeth, Inc., et al. v. Weeks " on Justia Law

Plaintiffs Jacklyn and Donald McMahon sued Defendants Yamaha Motor Corporation, U.S.A.; Yamaha Motor Manufacturing Corporation of America; Yamaha Motor Co., LTD. ("the Yamaha defendants"); and Montgomery Outdoor Power Products, Inc., d/b/a Montgomery Yamaha-Honda. They asserted a products-liability claim under the Alabama Extended Manufacturer's Liability Doctrine ("AEMLD"), as well as negligence, wantonness, breach-of-warranty, and loss-of-consortium claims. Jacklyn was injured in July 2007 when the 2007 Yamaha Rhino 660, a two-passenger off-road utility vehicle that the McMahons had purchased from Montgomery Yamaha-Honda, rolled over while she was driving it, resulting in injuries to her arms and legs when she extended them out of the vehicle in an attempt to support herself and/or the vehicle during the rollover. At the close of evidence, the McMahons withdrew their breach-of-warranty claim and the Yamaha defendants moved for a judgment as a matter of law on the remaining claims. After the jury returned a verdict in favor of the Yamaha defendants, the McMahons appealed the judgment on the negligence and wantonness claims. Upon further review, the Supreme Court affirmed in part and reversed in part. The Court found that the McMahons produced substantial evidence to support their wantonness claim and that the trial court accordingly erred by entering a judgment as a matter of law in favor of the Yamaha defendants on that claim. However, any error the trial court may have committed in entering a judgment as a matter of law in favor of the Yamaha defendants on the McMahons' negligence claim was harmless because the jury's verdict on their AEMLD claim established that their negligence claim would have been unsuccessful. View "McMahon v. Yamaha Motor Corporation, U.S.A., et al. " on Justia Law

Petitioner Delta International Machinery Corporation (Delta) sought a writ of mandamus to direct the circuit court to vacate an order that granted Respondent Brandon Landrum access to "certain technology" in its control. Respondent was operating a portable bench saw manufactured by Delta. His hand came into contact with the sawblade and ended with injuries to his hand and amputation of his index finger. In 2007, Respondent sued Delta alleging the saw was defective and unreasonably dangerous. Though the parties agreed to a protective order which forbade certain confidential materials from being released to Respondent's expert witness who happened to be employed by one of Delta's competitors, the trial court allowed Respondent's expert to review certain technology in Delta's possession pertaining to design of safety features of the saw. The technology Respondent sought to discover had pre-dated technology that had been developed by a joint venture of all saw manufacturers, of which Delta was a part. Delta claimed that its "flesh-sensing" technology was not discoverable because it did not exist at the time Respondent's saw was manufactured, and pre-dated the joint venture. Delta objected to Respondent's discovery request as "irrelevant" and "confidential." The trial court granted Respondent's motion to inspect. Delta subsequently filed its petition to the Supreme Court. Upon review, the Supreme Court found that the flesh-sensing technology was both a trade secret and was not relevant to Respondent's claims. As such, the Court concluded that the trial court exceeded its discretion in allowing discovery of that technology and in allowing access to the technology by Delta's competitor. The Court granted Delta's request for the writ, and directed the trial court directed the trial court to vacate its order granting Respondent's motion to inspect. View "Landrum v. Delta International Machinery Corp." on Justia Law