Justia Alabama Supreme Court Opinion Summaries

Dwight D. Sikes appealed a judgment from the Choctaw Circuit Court, where Michelle M. Kirkland, representing Kenneth McIlwain's estate, had obtained a judgment against him. The case involved land originally owned by Dwight's father, James Sikes, which was deeded to Dwight's brother, Archie, and subsequently to Kenneth and Patricia McIlwain. The McIlwains sued Dwight, alleging his livestock trespassed and caused damage. Dwight counterclaimed, alleging the McIlwains improperly removed James's personal property, and cross-claimed, arguing James was not competent when deeding the land to Archie.The Choctaw Circuit Court ordered Dwight to remove his livestock but did not rule on his counterclaim. After the McIlwains passed away, Kirkland was substituted as the plaintiff. The court later ruled against Dwight on his cross-claim, finding James competent when deeding the land, but did not address the counterclaim. Dwight appealed this judgment.The Supreme Court of Alabama reviewed the case and noted that the lower court had not disposed of all claims, specifically Dwight's counterclaim regarding the removal of personal property. The court emphasized that a final judgment must conclusively determine all issues and rights of the parties. Since the trial court's judgment did not address the counterclaim or fully resolve the initial trespass and nuisance claims, it was not a final judgment.Consequently, the Supreme Court of Alabama dismissed Dwight's appeal due to the lack of a final judgment, as the unresolved claims deprived the court of jurisdiction. View "Sikes v. Kirkland" on Justia Law

In February 2019, the Colberts entered into a real-estate sales contract with A & W Contractors, LLC to purchase a remodeled 54-year-old house. A home inspection revealed issues with the plumbing, septic system, and electrical wiring. The parties amended the contract to address these issues, and A&W claimed to have made the necessary repairs. Despite lingering concerns, the Colberts proceeded with the purchase after A&W's real-estate agent allegedly offered a three-month builder's warranty. After moving in, the Colberts experienced significant problems with the house's systems and spent approximately $90,000 on repairs.The Colberts sued A&W, and the case went to trial in the Jefferson Circuit Court. The jury found in favor of the Colberts on their breach-of-contract and fraud claims, awarding them compensatory and punitive damages. The trial court entered a judgment on the jury's verdict and denied A&W's post-trial motions to alter, amend, or vacate the judgment or for a new trial.The Supreme Court of Alabama reviewed the case. It held that the trial court erred in granting a judgment as a matter of law (JML) in favor of the Colberts on their breach-of-contract claim, as there was conflicting evidence that should have been resolved by the jury. However, the Supreme Court affirmed the jury's verdict on the fraudulent misrepresentation and fraudulent suppression claims, noting that A&W had failed to preserve certain evidentiary and sufficiency-of-the-evidence arguments for appellate review. The case was affirmed in part, reversed in part, and remanded for further proceedings consistent with the opinion. View "A & W Contractors, LLC v. Colbert" on Justia Law

American Pride Properties, LLC ("APP") filed a lawsuit in the Jefferson Circuit Court against James R. Davis and William M. Pickard, seeking ejectment and damages for the loss of use of real property owned by APP. Pickard had initially shown interest in purchasing the property and was allowed to take possession for renovations before closing. However, the sale did not close as planned, and Pickard attempted to assign his rights to Davis, which led to confusion. Despite multiple extensions and addendums to the purchase agreement, the sale never closed, and APP considered the agreement canceled.The Jefferson Circuit Court held a bench trial and ruled in favor of APP on its ejectment claim, awarding possession of the property to APP and dismissing the counterclaims filed by Davis and Pickard. However, the court retained jurisdiction over APP's demand for damages related to the use and detention of the property. The court certified its judgment as final under Rule 54(b) of the Alabama Rules of Civil Procedure, leading Davis and Pickard to appeal.The Supreme Court of Alabama reviewed the case and determined that the Rule 54(b) certification was improper because the trial court had not resolved the issue of damages, which was part of the same claim for ejectment. The court emphasized that a claim is not fully adjudicated for Rule 54(b) purposes until all elements, including damages, are resolved. Consequently, the judgment was not final, and the Supreme Court of Alabama dismissed the appeals as premature due to lack of jurisdiction. View "Davis v. American Pride Properties, LLC" on Justia Law

The case involves a dispute over the ownership of real property following the death of Billy Skidmore. Billy died intestate in July 2015, leaving behind two sons, John and Billy Jr. The Marshall Probate Court awarded John letters of administration over Billy's estate. Billy Jr. later filed a claim asserting his entitlement to an equal share of the estate. John filed an inventory listing the estate's assets, including a one-third interest in a commercial building. Billy Jr. moved to compel a final settlement, leading to a hearing where John admitted to commingling estate rental proceeds with his personal funds. The probate court subsequently appointed Billy Jr. as the successor administrator and authorized him to list the estate's real property for sale.John discovered a 2004 deed conveying the property to him and Billy as joint tenants with rights of survivorship, which he recorded in July 2023. Despite this, the probate court declared the property to be owned one-third each by John, Jenna (John's ex-wife), and Billy's estate. John removed the administration of the estate to the Marshall Circuit Court and filed a motion to alter, amend, or vacate the probate court's judgment. The circuit court denied his motion, leading John to appeal to the Supreme Court of Alabama.The Supreme Court of Alabama held that the Marshall Probate Court lacked jurisdiction to adjudicate the dispute over the title to the real property. The court emphasized that probate courts do not have the authority to determine equitable issues or administer equitable remedies, such as setting aside a recorded deed. Consequently, the Supreme Court reversed the circuit court's order and remanded the case for further proceedings consistent with its opinion. View "Skidmore v. Skidmore" on Justia Law

The City of Helena appealed a decision by the Shelby Circuit Court that allowed the Pelham Board of Education (PBE) to acquire, develop, and use a piece of real property within Helena's corporate limits for an athletic field and parking lot to serve Pelham High School students. The property, purchased by the PBE in 2021, is adjacent to Pelham High School but located within Helena. Helena argued that the PBE lacked the authority to construct and operate school facilities outside Pelham's corporate limits and that the project violated Helena's zoning ordinance.The Shelby Circuit Court ruled in favor of the PBE, stating that city zoning ordinances do not apply to governmental functions performed by a government body. The court found that the PBE's construction of the athletic field was a governmental function related to public education, which is exempt from local zoning regulations. Helena appealed, arguing that the PBE's actions were not authorized under Alabama Code § 16-11-9 and that the project did not comply with Helena's zoning ordinance.The Supreme Court of Alabama affirmed the circuit court's decision. The court held that § 16-11-9 does not restrict a city board of education's powers to the geographic boundaries of the city it serves. The court also concluded that the PBE's construction and operation of the athletic field constituted a governmental function related to public education, which is exempt from municipal zoning ordinances. Therefore, Helena's zoning ordinance could not be enforced against the PBE's project. The court affirmed the circuit court's order, allowing the PBE to proceed with the development and use of the property. View "City of Helena v. Pelham Board of Education" on Justia Law

The case revolves around a dispute over a property deed. Earnest Coprich and Bessie Elizabeth Jones, who have known each other for about 50 years, disagreed over the terms of a property sale. Coprich claimed that he sold his residence to Jones for $15,000, while Jones contended that the sale price was $10,000. After Jones moved into the property and made several improvements, Coprich filed a complaint seeking to set aside the deed. He alleged that he was mentally incompetent at the time of signing the deed and that he was coerced and defrauded by Jones. Jones denied these allegations and asserted that she had purchased the property and occupied it since the transaction.The Montgomery Circuit Court, after a bench trial, ruled in favor of Jones. The court found that Coprich failed to present sufficient evidence to prove his incompetence or that Jones had committed fraud or misrepresentation. Coprich's postjudgment motion to vacate the order was summarily denied by the court. Coprich then appealed to the Court of Civil Appeals, which transferred the appeal to the Supreme Court of Alabama due to lack of appellate jurisdiction.The Supreme Court of Alabama, however, determined that the Court of Civil Appeals should have jurisdiction over the case. The court noted that the case is a "civil case" as defined by § 12-3-10 and that the "amount involved" does not exceed the jurisdictional threshold of $50,000. Therefore, the Supreme Court transferred the appeal back to the Court of Civil Appeals. View "Coprich v. Jones" on Justia Law

The case involves Stacy G. Coats and Kendall Coats (the plaintiffs) who filed a private right-of-way condemnation case against Sandra F. Ayers, Tommy J. Ayers, and J. Jason Ayers (the defendants). The plaintiffs sought a right-of-way across the defendants' property to access their own landlocked properties. The properties in question include several parcels of land, some of which are low-lying wetlands often flooded and used for hunting and fishing. A private dirt road, referred to as the "farm road," crosses the defendants' property and has been historically used by the plaintiffs and their predecessors to access their properties.The Tuscaloosa Probate Court initially granted the plaintiffs a right-of-way across the defendants' property, concluding that the plaintiffs' property was landlocked. The defendants appealed this decision to the Tuscaloosa Circuit Court. The defendants argued that the plaintiffs' property was no longer landlocked due to inheritance of additional land that touched a public road. The Circuit Court agreed with the defendants, granting a summary judgment in their favor on the grounds that the plaintiffs' property was no longer landlocked and they had reasonable access to their property from a public road.The Supreme Court of Alabama reversed the decision of the Tuscaloosa Circuit Court. The Supreme Court found that there was a genuine issue of material fact regarding whether the plaintiffs have an existing, reasonable means to access their landlocked property. The court noted that the plaintiffs had presented substantial evidence indicating that they could not travel from the public road across their property to access their landlocked property. The court concluded that the plaintiffs had permission to cross an intervening property, and thus there was no requirement for them to seek a right-of-way over it. The case was remanded for further proceedings. View "Coats v. Ayers" on Justia Law

In 2010, Crystal Kaye Coan purchased a property in Lauderdale County, which was subject to a mortgage. Coan defaulted on the mortgage, leading to a foreclosure by Carrington Mortgage Services, LLC, the mortgage assignee. Carrington sold the property to Championship Property, LLC in an online auction in May 2018. Championship then filed an ejectment action against Coan, claiming it was the title owner and seeking possession of the property. Coan countered that the foreclosure sale was void, and therefore, Championship had not acquired the title. In January 2023, Championship requested the trial court to require Coan to deposit $2,000 per month with the court clerk pending a final ruling in the ejectment action. The trial court, over Coan's objection, ordered her to deposit $800 per month.Coan failed to deposit the court-ordered payments for March, April, and May 2023, leading Championship to move the trial court to hold her in contempt. The trial court found Coan in contempt and, as a sanction, ruled in favor of Championship on its ejectment claim, awarding it possession of the property. Coan appealed this decision.The Supreme Court of Alabama affirmed the trial court's decision to require Coan to deposit $800 per month with the court clerk, stating that the trial court had the authority to enter the escrow order. The court also affirmed the trial court's finding of contempt against Coan for failing to comply with the escrow order. However, the court reversed the trial court's sanction awarding Championship possession of the property, stating that the sanction was not appropriate given the current posture of the litigation. The case was remanded to the trial court for further proceedings consistent with the Supreme Court's opinion. View "Coan v. Championship Property, LLC" on Justia Law

Harold Wallace, a tenant of the Housing Authority of the City of Talladega, fell while descending the back-porch stairs of his apartment due to missing handrails. Wallace sued the Housing Authority for negligence and wantonness. The Housing Authority moved for a summary judgment, arguing that the lack of handrails was an "open and obvious" danger and that Wallace had conceded in his deposition that he was aware of this. The trial court granted the Housing Authority's motion for a summary judgment. Wallace appealed to the Court of Civil Appeals.The Court of Civil Appeals reversed the trial court's summary judgment in favor of the Housing Authority. The Housing Authority then petitioned the Supreme Court of Alabama for certiorari review, arguing that the Court of Civil Appeals' decision conflicts with a prior decision in Daniels v. Wiley, where the court affirmed a summary judgment for the defendant landlord after concluding that the landlord had no duty to the plaintiff tenant with respect to risks created by the muddy condition of a sidewalk within her apartment complex because the danger was "open and obvious."The Supreme Court of Alabama affirmed the decision of the Court of Civil Appeals, concluding that the decision does not conflict with Daniels. The court clarified that while the Daniels decision is sound, it should not be interpreted as rejecting a landlord's duties under the circumstances described in §§ 360 and 361 of the First Restatement and the Second Restatement. The court found that the Housing Authority failed to raise a genuine issue of material fact as to whether the principles set forth in §§ 360 and 361 apply to the circumstances in this case, and therefore, the Housing Authority was not entitled to a judgment as a matter of law. View "Ex parte The Housing Authority of the City of Talladega" on Justia Law

The Supreme Court of Alabama reviewed a case involving a dispute over an undeveloped island ("the island") located within a canal system on Ono Island, a residential subdivision. The island was created during the development of the canal system and was later sold in a tax sale. F Family South, LLC ("FFS") acquired the island and sought to construct a boat shelter on it. The Property Owners Association of Ono Island, Inc. ("the POA") objected, arguing that the island was subject to certain covenants restricting its use.The Baldwin Circuit Court ruled in favor of the POA, finding that the island was subject to both express and implied covenants restricting its use. The court also invalidated the 1995 tax sale through which FFS had obtained ownership of the island, and declared the POA as the island's owner.FFS appealed, arguing that the trial court erred in voiding the 1995 tax sale and in concluding that the island was subject to the covenants. The Supreme Court of Alabama reversed the trial court's decision to void the tax sale, but affirmed the finding that the island was subject to implied restrictive covenants governing its use. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "F Family South, LLC v. Property Owners Association of Ono Island, Inc." on Justia Law