Justia Alabama Supreme Court Opinion Summaries

A property dispute arose when the estate of William King sold a property on Broad Street in Gadsden to Mobile Investments, LLC, in 2019. Corporate Pharmacy Services, Inc. (CPS), which had originally leased the property from King, claimed the lease included an option to purchase the property and that King’s estate improperly sold it without giving CPS the opportunity to exercise its right of first refusal. CPS sued Mobile Investments and The Broadway Group, LLC (TBG), alleging breach of the lease and seeking specific performance of the purchase option. After Mobile Investments and TBG repeatedly failed to comply with discovery requests and court orders, the Etowah Circuit Court entered a default judgment against them, ordering that CPS was entitled to purchase the property for $110,000.Mobile Investments and TBG first moved for relief from the default judgment, which was denied. They appealed to the Supreme Court of Alabama, arguing they had not been properly informed by their counsel about discovery orders and their consequences. The Supreme Court of Alabama affirmed the trial court’s judgment. Afterward, Mobile Investments and TBG filed a Rule 60(b)(4) motion, later amended to add Rule 60(b)(6) grounds, seeking to set aside the judgment as void for lack of due process and to correct the property description. The trial court denied the motion in large part but scheduled a further hearing to resolve issues regarding the legal description of the property and the corresponding purchase price.Before the trial court could complete its proceedings on these unresolved issues, Mobile Investments and TBG appealed again to the Supreme Court of Alabama. The Supreme Court of Alabama held that because the trial court had not yet issued a final judgment—leaving substantive issues pending—it lacked jurisdiction over the appeal. Accordingly, the appeal was dismissed. View "Mobile Investments, LLC v. Corporate Pharmacy Services, Inc." on Justia Law

A real estate investment firm based in China and another firm based in Singapore entered into a joint venture in 2021 to develop and operate a property near Auburn University. The Chinese firm held an 80% interest, while the Singaporean firm held a 20% interest and managed the venture, with full access to the joint venture’s bank accounts. The Chinese firm alleged that the manager firm made unauthorized transfers from the joint venture’s accounts, ultimately taking over $1 million. Despite partial repayment and assurances, a significant amount remained outstanding.The Chinese firm filed suit in the Lee Circuit Court, Alabama, asserting claims including declaratory judgment, fraudulent misrepresentation, conversion, and fraudulent suppression. The Singaporean firm failed to timely respond to the complaint, leading to requests for default judgment. After some delay, the manager filed an answer and engaged in discovery, but disputes arose over depositions and compliance with court orders. The trial court repeatedly addressed motions for default judgment and issues of discovery noncompliance, particularly regarding the failure of the manager’s CEO to appear for deposition. The manager later moved to compel arbitration, citing joint venture agreements containing arbitration clauses; however, the trial court ultimately entered a default judgment on liability for the Chinese firm, reserving damages, and deemed the motion to compel arbitration moot.On appeal, the Supreme Court of Alabama considered whether it had jurisdiction, given that the lower court’s judgment did not resolve damages. The Supreme Court of Alabama held that the order was interlocutory and not appealable because it did not determine damages. The court concluded that the default judgment’s interlocutory nature was not altered by the ruling on the arbitration motion, and accordingly, dismissed the appeal for lack of a final judgment. View "Ivy Fund Manager, LLC v. CDH Real Estate Investment Management Company, Ltd." on Justia Law

A motorcyclist suffered severe injuries after crashing on Avenue V in Birmingham due to a defect in the road. He submitted a notice of claim to the City of Birmingham within six months as required by state law and later filed a negligence lawsuit, alleging the City failed to repair the defect after being notified. The key factual dispute involved whether the City had actual or constructive knowledge of the defect prior to the accident.The Jefferson Circuit Court reviewed the case and, after discovery, denied the City’s initial motion for summary judgment. The City later renewed its motion, attaching new evidence and seeking to strike some of the plaintiff’s evidence. The trial court struck several items, including an affidavit, an unsworn witness statement, and a patient-care report, but again denied summary judgment. The City’s motion for reconsideration was denied, prompting it to petition for a writ of mandamus.The Supreme Court of Alabama reviewed the petition, focusing on whether the City was entitled to municipal immunity. Applying a de novo standard, the court found that the admissible evidence did not create a genuine issue of material fact as to whether the City had actual or constructive knowledge of the defect. The court held that the plaintiff’s remaining evidence was speculative and insufficient to overcome the City’s prima facie case for immunity. The court granted the City’s petition, issued the writ of mandamus, and directed the trial court to vacate its order denying summary judgment and instead grant summary judgment in favor of the City. View "In re: Stoudmire v. City of Birmingham" on Justia Law

A Mississippi construction company, operating under the name MCA Construction, Inc., entered into a contract with an Alabama property owner to perform site development work on a residential subdivision in Baldwin County. The contract was executed on February 11, 2021, and at that time, the company held an Alabama general contractor’s license with a “Building Construction” (BC) classification and an unlimited bid limit. Shortly before executing the contract, the city engineer raised questions regarding whether the BC classification was adequate for the planned utility work (such as water and sewer installation) and indicated that an additional “Municipal and Utility” (MU) classification might be required before such work began. MCA sought clarification from the state licensing board and subsequently obtained the MU classification in May 2021, before starting the utility work.The property owner, RAM-Robertsdale Subdivision Partners, LLC, along with related parties, later alleged that MCA had performed defective work and failed to pay subcontractors, and they brought suit in Baldwin Circuit Court. MCA filed counterclaims for breach of contract and fraud, asserting that it had not been fully paid for its work. The RAM parties moved for summary judgment, arguing that the contract was void because MCA was not properly licensed with the MU classification at the time the contract was executed.The Baldwin Circuit Court granted summary judgment for the RAM parties, holding that the contract was void because MCA was not “duly licensed” for all aspects of the work at the time of contracting. MCA appealed. The Supreme Court of Alabama reviewed the statutory and regulatory framework, noting that MCA had a valid BC license, acted in good faith, and obtained the MU classification before performing utility work. The Supreme Court of Alabama held that substantial compliance with the licensing statute was sufficient in these circumstances and that voiding the contract was not warranted. The court reversed the summary judgment and remanded for further proceedings. View "Construction Services, LLC v. RAM-Robertsdale Subdivision Partners, LLC" on Justia Law

A house in Hoover, Alabama was owned by William and Roberta as joint tenants with rights of survivorship. After William’s death in 2012, Roberta remained at the property, later joined by her son, Parker, who eventually married Hall. Roberta died in 2019, and Parker claimed he became the property owner as her sole heir. The mortgage, originally executed with Countrywide Home Loans and later assigned to The Bank of New York Mellon (BONY), went into default, leading to foreclosure in 2021. BONY purchased the property at foreclosure, but Parker and Hall did not vacate. BONY filed an ejectment action in 2022, initially naming William and Roberta (both deceased) as defendants, later substituting Parker, Hall, and the estate of Roberta.The Shelby Circuit Court granted summary judgment for BONY and Select Portfolio Servicing (SPS), ordering Parker and Hall to make payments into court, granting BONY immediate possession, declaring Parker and Hall forfeited any right of redemption for failing to vacate, and granting judgment against their counterclaims.The Supreme Court of Alabama reviewed the case and first addressed whether the circuit court had subject-matter jurisdiction. The Supreme Court held that, because the original complaint only named deceased persons as defendants, the action was void from its inception and did not invoke the jurisdiction of the trial court. Consequently, the circuit court had no authority to entertain amendments, substitute the estate, or address any further motions or pleadings. The Supreme Court of Alabama reversed the lower court’s order and remanded with instructions for the trial court to vacate its order and dismiss the action, without prejudice. This disposition was based solely on the jurisdictional defect, pretermitting other arguments. View "Parker v. The Bank of New York Mellon" on Justia Law

A real estate transaction in Shelby County, Alabama, gave rise to this dispute. In 2007, a property owner named Ellison financed the purchase of her home with a loan secured by a mortgage, which was eventually sold to U.S. Bank Trust National Association and serviced by SN Servicing Corporation. After Ellison defaulted, U.S. Bank bought property at a foreclosure sale. Due to confusion over addresses and a lack of a survey, U.S. Bank and its agent mistakenly believed they were selling the Ellison property, a valuable bricked double-wide trailer, to Marco J. Bonilla. Bonilla purchased the property for $95,000, but later discovered that the deed conveyed a different and less valuable property. He was unable to resell the property he believed he owned.Bonilla sued U.S. Bank and SN Servicing in the Shelby Circuit Court, asserting claims for conversion, breach of contract, negligence, wantonness, and sought rescission of the deed. Both sides moved for summary judgment. The circuit court granted summary judgment for Bonilla on all claims, rescinded the transaction, ordered Bonilla to execute a quitclaim deed returning the property, and awarded him $114,000 in compensatory damages, $14,913.70 in interest, and $75,000 in punitive damages for wantonness. The court denied the defendants’ postjudgment motion without a hearing.On appeal, the Supreme Court of Alabama affirmed summary judgment for Bonilla on his claims for conversion, breach of contract, and negligence, as well as the compensatory and interest awards. However, the Court reversed the summary judgment on the wantonness claim and the award of punitive damages, holding that wantonness involves disputed factual issues concerning the defendants’ mental state that should be determined by a jury. The case was remanded for further proceedings on wantonness and punitive damages. View "U.S. Bank Trust National Association v. Bonilla" on Justia Law

Shirley R. Hulsey and her husband purchased a residence in Tuscaloosa, Alabama, which was adjacent to a vacant lot owned by Yellow Hammer Capital Management, LLC. In 2017, Build Art, LLC was retained by Yellow Hammer to construct a residence on the adjacent lot, which was at a higher elevation and sloped toward Hulsey’s property. After construction began, Hulsey observed water and debris flooding her property, which she attributed to changes in the grading and runoff from the construction. She alleged that the construction caused damage to her home’s foundation and sought damages and injunctive relief against Build Art, Yellow Hammer, and unnamed defendants, claiming trespass, nuisance, negligence, wantonness, emotional distress, and violation of her common-law rights concerning surface water flow.The Tuscaloosa Circuit Court granted summary judgment in favor of Build Art on all claims against it, while the claims against Yellow Hammer and other defendants remained pending. Hulsey moved for reconsideration, which was denied. The court subsequently certified the summary judgment as final under Rule 54(b) of the Alabama Rules of Civil Procedure, allowing Hulsey to file an appeal to the Supreme Court of Alabama.The Supreme Court of Alabama reviewed whether the trial court’s order was a final judgment suitable for appeal. The Supreme Court determined that the claims against Build Art and Yellow Hammer were so closely intertwined, arising from the same operative facts, that certifying the summary judgment as final was improper. The Supreme Court held that such certification posed risks of inconsistent results and wasted judicial resources. Consequently, the Supreme Court dismissed the appeal, finding that the order was not a final judgment capable of supporting appellate review. View "Hulsey v. Build Art, LLC" on Justia Law

The dispute arose from a contract signed on May 12, 2021, under which Kindra Cooper agreed to purchase a house from Highland Rim Investments, LLC. Delays in closing led the parties to enter into three extensions, but the sale never concluded. Cooper then sued for specific performance, declaratory judgment, and damages, later amending her complaint to add additional defendants and claims, including various forms of misrepresentation and a request to pierce Highland Rim’s corporate veil. During litigation, certain claims were dismissed, and after a jury trial, the jury awarded Cooper compensatory and punitive damages against Highland Rim and Monique Dollone, but found for other defendants on the misrepresentation claims.The Madison Circuit Court entered judgment on the jury's verdict, awarded Cooper attorney fees, granted her motion to pierce the corporate veil as to one defendant, and later appointed a receiver over Highland Rim to preserve its fiscal health until the judgment was satisfied. The defendants moved for post-judgment relief, which was denied, and then appealed both the judgment and the receivership order.The Supreme Court of Alabama reviewed the appeals. It found that the trial court erred by requiring the parties to strike the jury from a list of only 21 prospective jurors, rather than the 24 required by Alabama Rule of Civil Procedure 47(b). This procedural error mandated reversal. The Supreme Court of Alabama held that the trial court’s judgment in favor of Cooper and its order appointing a receiver over Highland Rim must be reversed. The cases were remanded for further proceedings consistent with this opinion. View "Highland Rim Investments, LLC v. Cooper" on Justia Law

The dispute arose after Will Pecue contracted with Gulf Coast Dock Masters/H5K Company, LLC, represented by Ryan Hess, to replace two piers near Pecue's residence. One pier, the "harbor pier," was completed and paid for in full, while the other, the "social pier," was left unfinished after Pecue terminated the contract. Pecue became dissatisfied upon discovering that nontreated lumber was used on the social pier, contrary to contract specifications. Although some boards were replaced, Pecue claimed Hess refused to fix all affected areas and ultimately sent a notice of default. Pecue also asserted that H5K was not a legitimate business entity, which he argued prevented him from obtaining contractual remedies.The Baldwin Circuit Court held a bench trial, during which Pecue pursued only a fraud claim against Hess and H5K, seeking substantial damages. Pecue testified about the alleged misrepresentation of H5K's existence and Hess's refusal to remedy the workmanship issues. The trial court entered judgment in favor of Pecue for $100,000 against Hess and "Ryan Hess D/B/A Gulf Coast Dock Masters." Hess filed a postjudgment motion challenging the sufficiency of the evidence for fraud, but the motion was denied.The Supreme Court of Alabama reviewed the case, applying both the ore tenus and de novo standards of review as appropriate. The court found that the evidence did not support Pecue's claim of fraud. Specifically, there was no misrepresentation of material fact regarding H5K’s existence, and any alleged misrepresentation did not proximately cause Pecue’s damages. Further, there was no evidence of promissory fraud. The Supreme Court of Alabama reversed the trial court’s judgment and remanded the case with instructions to enter judgment in favor of Hess on Pecue’s fraud claim. View "Hess v. Pecue" on Justia Law

After both parents contracted COVID-19 in 2020, they asked their daughter to move from Tennessee to Alabama to care for them. In exchange for her agreement to relocate and provide care, the parents promised to convey an interest in their Orange Beach condominium to the daughter. The parents, acting in their individual capacities, executed a deed purporting to transfer an interest in the property to themselves and their daughter as joint tenants. The daughter was not aware that the condominium was, in fact, owned by a revocable trust for which the parents served as trustees.The parents later sought to annul the deed in the Baldwin Circuit Court, arguing that the deed was ineffective because the property was owned by the trust and they had not executed the deed as trustees. They also contended that the conveyance was voidable under Alabama law because a material part of the consideration was the daughter’s promise to support them. The daughter sought reformation of the deed to reflect the parents' trustee status and counterclaimed for fraud and breach of warranty. The Baldwin Circuit Court annulled the deed and dismissed the daughter’s counterclaims.The Supreme Court of Alabama reviewed the case. It held that the controlling statute, § 8-9-12, Ala. Code 1975, permitted annulment of a real property conveyance when a material part of the consideration was an agreement to provide support, regardless of whether the grantor acted as an individual or trustee. The Court further held that annulment of the deed extinguished any warranties arising from the conveyance and rendered the fraud counterclaim untenable. Accordingly, the Supreme Court of Alabama affirmed the judgment, upholding annulment of the deed and dismissal of the counterclaims. View "Schumpert v. Wallace" on Justia Law