Justia Alabama Supreme Court Opinion Summaries

A firefighter employed by the City of Birmingham developed hypertension during his employment and applied to the City of Birmingham Retirement and Relief System for both extraordinary and ordinary disability benefits, arguing that his condition and the medications required to control it prevented him from safely performing his job. He detailed unsuccessful attempts to manage his hypertension with various medications and provided medical opinions supporting his claim that only beta-blockers, which are not recommended for firefighters, could control his blood pressure. The Board, after considering the opinion of its medical expert, denied both applications, concluding that he had not exhausted all other antihypertensive regimens.The firefighter sought review of the Board’s decisions by filing a petition for a writ of mandamus in the Jefferson Circuit Court, as permitted by statute. Initially, the circuit court dismissed the action for lack of service, but the Supreme Court of Alabama reversed that dismissal and remanded the case. After service was obtained, the respondents argued that the claim for extraordinary disability benefits failed as a matter of law because the hypertension was not caused by a specific workplace accident, and that the Board’s denial of ordinary disability benefits was not manifestly wrong. The circuit court denied the mandamus petition without a hearing or consideration of evidence beyond the pleadings.The Supreme Court of Alabama affirmed the circuit court’s denial of extraordinary disability benefits, holding that the statutory requirements were not met because the disability did not result from an accident at a definite time and place. However, the Supreme Court reversed the denial of ordinary disability benefits, finding that the circuit court erred by not allowing the petitioner to present evidence or reviewing the evidence considered by the Board. The case was remanded for further proceedings on the ordinary disability claim. View "Hoffman v. City of Birmingham Retirement and Relief System" on Justia Law

A group of plaintiffs filed suit against the Secretary of the Alabama Department of Workforce, alleging that the Department’s handling of their unemployment benefits applications during the COVID-19 pandemic was unlawful. The plaintiffs claimed that the Department’s policies and practices resulted in unreasonable delays and inadequate communication, violating both the Social Security Act and the Due Process Clause of the Fourteenth Amendment. They sought various forms of injunctive relief, including orders requiring prompt decisions on applications, timely payment of approved claims, and clearer communication with claimants.The Montgomery Circuit Court granted the Secretary’s motion to dismiss the case, without specifying the grounds for dismissal. The plaintiffs’ motion to alter or vacate the judgment was denied. On appeal, the Supreme Court of Alabama affirmed the dismissal, holding that the plaintiffs had not exhausted their administrative remedies and that the courts lacked the power to address the merits of their claims. The plaintiffs then sought review by the United States Supreme Court.The United States Supreme Court reversed the Alabama Supreme Court’s judgment, holding that the state’s administrative exhaustion requirement could not be used to bar federal due process claims under 42 U.S.C. § 1983 for alleged delays in processing unemployment benefits. On remand, the Supreme Court of Alabama considered supplemental briefing on whether the case had become moot, as the Secretary asserted that all plaintiffs had either been paid or received final denials. The plaintiffs disputed this and requested a remand for a factual determination. The Supreme Court of Alabama remanded the case to the Montgomery Circuit Court to determine whether the case is now moot, instructing the lower court to resolve the factual dispute regarding mootness. View "Johnson v. Reed" on Justia Law

With the onset of COVID-19, the Alabama Department of Labor received a record number of applications for unemployment benefits. The Department struggled to process the additional million-plus applications in a timely fashion. The plaintiffs-appellants in this case were among the many individuals who experienced delays in the handling of their applications. They brought this lawsuit in an effort to jumpstart the administrative-approval process. In their operative joint complaint, each plaintiff raised multiple claims for relief, all of which sought to compel the Alabama Secretary of Labor, Fitzgerald Washington, to improve the speed and manner in which the Department processes their applications for unemployment benefits. Secretary Washington responded to the suit by asking the circuit court to dismiss all claims against him, arguing (among other things) that the circuit court lacked jurisdiction over the suit because the plaintiffs had not yet exhausted mandatory administrative remedies. After the circuit court granted that motion, the plaintiffs appealed to the Alabama Supreme Court. The Supreme Court agreed with Secretary Washington that the Legislature prohibited courts from exercising jurisdiction over the plaintiffs' claims at this stage. The Court therefore affirmed the circuit court's judgment of dismissal. View "Johnson, et al. v. Washington" on Justia Law

In response to economic conditions related to the spread of COVID-19, Congress established several programs that made additional federal funds available to the states for providing enhanced unemployment-compensation benefits to eligible individuals. Alabama elected to participate in the programs, and Shentel Hawkins, Ashlee Lindsey, Jimmie George, and Christina Fox, were among the Alabamians who received the enhanced benefits. As the spread of COVID-19 waned, Governor Kay Ivey announced that Alabama would be ending its participation in the programs. When Alabama did so, the claimants received reduced unemployment-compensation benefits or, depending on their particular circumstances, no benefits at all. Two months later, the claimants sued Governor Ivey and Secretary of the Alabama Department of Labor Fitzgerald Washington in their official capacities, alleging that Alabama law did not permit them to opt Alabama out of the programs. After a circuit court dismissed the claimants' lawsuit based on the doctrine of State immunity, the claimants appealed. Finding no reversible error, the Alabama Supreme Court affirmed the circuit court. View "Hawkins, et al. v. Ivey, et al." on Justia Law

John Boman appealed the grant of summary judgment in favor of the City of Gadsden. Boman worked as a Gadsden police officer from 1965 until he retired in 1991. Following his retirement, Boman elected to pay for retiree health coverage through a group plan offered by Gadsden to retired employees. This retired-employee-benefit plan was also administered by Blue Cross and provided substantially similar benefits to those Boman received as an active employee. In 2000, however, Gadsden elected to join an employee-health-insurance-benefit plan ("the plan") administered by the State Employees' Insurance Board ("the SEIB"). When Boman turned 65 in 2011, he was receiving medical care for congestive heart failure and severe osteoarthritis of the spine. After his 65th birthday, Blue Cross began denying his claims for medical treatment based on the failure to provide Blue Cross with a "record of the Medicare payment." However, Boman had no Medicare credits. Boman was hired before March 31, 1986, and, although Gadsden did begin participation in the Medicare program in 2006, Boman's employee group had not opted to obtain Medicare coverage before Boman retired. Consequently, Boman never paid Medicare taxes and did not claim to have Medicare coverage. The SEIB ultimately determined that the plan was the secondary payer to Medicare. Boman sued Gadsden, asserting that it had broken an agreement, made upon his employment, to provide him with lifetime health benefits upon his retirement. Boman also sued the members of the SEIB charged with administering the plan, challenging the SEIB's interpretation of the plan. Finding no reversible error in the grant of summary judgment to Gadsden, the Supreme Court affirmed. View "Boman v. City of Gadsden" on Justia Law

The City of Gadsden and certain members of the State Employees' Insurance Board appealed two circuit court orders that granted injunctive relief to John Boman. Boman worked as a Gadsden police officer from 1965 until he retired in 1991. In 2000, Gadsden elected to join the 'Local Government Health Insurance Plan,' a health benefit plan administered by the Board. When Boman turned 65 in 2011, he was receiving medical care for congestive heart failure and other ailments. After his 65th birthday, Blue Cross began denying his claims for medical treatment based on the failure to provide Blue Cross with a 'record of the Medicare payment.' However, Boman had no Medicare credits. When the dispute over coverage arose, Boman sought review by the Board. The Board denied Boman's request for an appeal. Boman and 18 other active and retired Gadsden police officers sued Gadsden, alleging, among other things, that they had 'been deprived of Social Security and Medicare protection which other police officers have been provided' and that, after 20 years of service, they were being required to pay a higher pension charge or percentage of base pay than their counterparts who were hired after April 1, 1986. In 2011, Boman filed a 'motion for immediate relief for medical care.' The Supreme Court found that the circuit court issued preliminary injunctive relief against Gadsden without requiring Boman to give security and without making any specific findings. As such, the Supreme Court had "no alternative but to reverse" the preliminary injunction issued against Gadsden and remanded the case for further proceedings. View "City of Gadsden v. Boman " on Justia Law

The City of Gadsden appealed an order of injunctive relief in favor of John Boman, a retired Gadsden police officer. Boman and 18 other active and retired Gadsden police officers sued Gadsden alleging, among other things, that they had "been deprived of Social Security and Medicare protection which other police officers have been provided" and that, after 20 years of service, they were being required to pay a higher pension charge or percentage of base pay than their counterparts who were hired after April 1, 1986. Boman filed a "motion for immediate relief for medical care." He alleged that when he was hired, Gadsden "provided police and firemen a 20 year retirement program whereby police and firemen would receive 50% retirement benefits after 20 years of service and lifetime medical care." He averred that Gadsden had "breached its contract with [him] to provide continuing medical insurance," and he requested "immediate relief by ordering [Gadsden] to pay for [his] medical care or in the alternative ordering [Gadsden] to pay for Medicare coverage for ... Boman so he will have continuing medical insurance as agreed by the Board filed a motion to dismiss the action as to it and the plan. As to it, the Board alleged that it was an agency of the State and, therefore, was entitled to absolute immunity from suit. Also, according to the Board, the plan is not a legal entity subject to suit, but "merely a program administered by the Board to provide insurance." It also averred that, "[e]ven if [the plan] were an entity subject to suit, it would be immune for the same reasons [the] Board is immune." Boman's response to the Board's motion failed to acknowledge or mention the immunity question. The trial court, without conducting an evidentiary hearing, entered an "order granting motion for emergency relief." It ultimately dismissed the claims against the Board and the plan. Gadsden appealed. Upon review, the Supreme Court reversed based on the failure to join the officials of the Board, in their official capacities, as necessary parties. On remand, the trial court was directed to entertain an amendment to the complaint adding claims against those officials of the Board who are charged with administering the plan, in their official capacities. View "City of Gadsden, Alabama v. Boman et al. " on Justia Law

Main & Associates, Inc., d/b/a Southern Springs Healthcare Facility, filed an action in the Bullock Circuit Court, on behalf of itself and a putative class of Alabama nursing homes, against Blue Cross and Blue Shield of Alabama (BCBS), asserting claims of breach of contract, intentional interference with business relations, negligence and/or wantonness, and unjust enrichment and seeking injunctive relief. BCBS removed the case to the the federal court, arguing among other things, that Southern Springs' claims arose under the Medicare Act and that the Medicare Act, as amended by the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (the MMA) completely preempted Southern Springs' state-law claims. Southern Springs moved the federal court to remand the case to the circuit court, arguing that the federal court did not have jurisdiction over its claims. The federal court granted the motion and remanded the case to the Bullock Circuit Court. After remand, BCBS moved the circuit court for a judgment on the pleadings, arguing that Southern Springs had not exhausted its administrative remedies and that the circuit court did not have subject-matter jurisdiction over the case. The circuit court denied BCBS's motion, and BCBS petitioned the Supreme Court for a writ of mandamus to direct the circuit court to dismiss Southern Springs' claims. Upon review, the Court concluded that Southern Springs' claims were inextricably intertwined with claims for coverage and benefits under the Medicare Act and that they were subject to the Act's mandatory administrative procedures and limited judicial review. Southern Springs did not exhaust its administrative remedies, and the circuit court did not have jurisdiction over its claims. Therefore, the Court granted BCBS's petition and issue a writ of mandamus directing the circuit court to dismiss the claims against BCBS. View "Main & Associates, Inc. v. Blue Cross & Blue Shield of Alabama" on Justia Law

Plaintiff Jerry Elliott sought workers' compensation benefits from his employer, International Paper Company, Inc. (IP). He petitioned the Supreme Court for a writ of mandamus to quash a Court of Civil Appeals' writ of mandamus directed to the Conecuh Circuit Court. Plaintiff lived in Conecuh County for over 15 years and for 21 years worked as a machine operator at the plywood-manufacturing plant owned by IP located in Butler County. In 2007, he allegedly sustained an injury to his shoulder while at work. He filed an action at the Conecuh Circuit Court seeking workers' compensation benefits. IP filed motions to dismiss Plaintiff's action or, in the alternative, to transfer the case to Butler County. After a hearing, the trial court denied the motions to dismiss or to transfer. IP then filed a petition for the writ of mandamus at the Court of Civil Appeals to review the trial court's denial of its motion. The Court of Appeals granted the writ directing the Conecuh Court to transfer the case to Butler County. Upon review, the Supreme Court concluded the appellate court's decision was in error, and quashed the writ that was issued transferring venue to Butler County. View "Elliott v. International Paper Co., Inc." on Justia Law