Justia Alabama Supreme Court Opinion Summaries

Christopher Floyd was convicted for the 2005 murder of Waylon Crawford, for which he was sentenced to death. The Alabama Supreme Court issued a writ of certiorari to determine whether the following holdings of the Court of Criminal Appeals in Floyd's appeal of his capital-murder conviction were proper: that the the trial court did not err in holding that the State provided valid race- and gender-neutral reasons for its exercise of its peremptory strikes during jury selection; that the trial court did not err by refusing to admit into evidence all of Floyd's statements made to law-enforcement officers; and that the trial court did not err in denying Floyd's motion for a new trial based on newly discovered evidence. Finding no reversible error, the Supreme Court affirmed. View "Ex parte Christopher Floyd" on Justia Law

Nicholson Manufacturing Limited petitioned for a writ of mandamus to direct the Tuscaloosa Circuit Court to enter a summary judgment in its favor on the ground that Gerald Templeton's substitution of Nicholson for a fictitiously named defendant was made after the expiration of the applicable statutory limitations period and did not "relate back" to the filing of the original complaint. After review, the Supreme Court concluded Nicholson established it had a clear legal right to the relief requested. The Court granted the petition and issued the writ. View "Ex parte Nicholson Manufacturing Ltd." on Justia Law

Gudel AG, one of several defendants to this case, petitioned for a writ of mandamus to direct the Crenshaw Circuit Court to vacate its order denying Gudel's motion to dismiss the personal-injury claims filed against it by Robert and Cindy Rutledge, and to enter an order dismissing the Rutledges' claims on the basis of a lack of in personam jurisdiction. In February 2013, Robert sued Smart Alabama, LLC ("SAL"), an automotive-parts manufacturer located in Crenshaw County, seeking to recover worker's compensation benefits in connection with an alleged work-related injury Robert suffered in November 2011 while in SAL's employ. In November 2013, Robert amended his original complaint to add a count pursuant to Alabama's Extended Manufacturer's Liability Doctrine as well as negligence and wantonness claims. In addition, the amended complaint added both Hyundai WIA ("Hyundai") and Gudel, as well as several fictitiously named entities, as defendants. The amended complaint alleged that Gudel, a foreign corporation headquartered in Switzerland, "designed, built, manufactured, tested and sold [the] subject machine/equipment that is the subject matter of [the Rutledges'] lawsuit." After review, the Supreme Court held that the trial court exceeded its discretion in determining that it possessed personal jurisdiction over Gudel. Accordingly, Gudel has established a clear legal right to the dismissal of the claims against it; therefore, the Alabama Court granted the petition and directed the trial court to vacate its order denying Gudel's motion to dismiss and to dismiss the Rutledges' claims against Gudel. View "Ex parte Gudel AG." on Justia Law

Fairfield Nursing and Rehabilitation Center, LLC; D&N, LLC; DTD HC, LLC; Aurora Cares, LLC (alleged to be doing business as "Tara Cares"); and Aurora Healthcare, LLC (collectively, "the defendants"), petitioned for a writ of mandamus to direct the trial court to vacate its February 6, 2015, order denying their "Motion to Quash Depositions and Motion for Protective Order, and Motion to Reconsider January 30, 2015[,] Order." The defendants also requested that the Supreme Court direct the trial court to grant their motion. In May 2006, Myrtis Hill was a patient at Fairfield. While under Fairfield's care, Hill suffered a broken leg when a Fairfield employee, while attempting to transfer Hill to a bedside commode, allegedly dropped her to the floor thereby breaking Hill's right leg and causing severe injury to both of her legs. After review of the trial court record, the Supreme Court concluded the defendants demonstrated they had a clear legal right to the relief they requested, and that the trial court clearly exceeded its discretion in denying the defendants' motion for a protective order. Hill's "Motion for Award of Damages based on [the defendants'] pattern and practice of filing frivolous appeals" was denied. View "Ex parte Fairfield Nursing & Rehabilitation Center, LLC" on Justia Law

On or about August 1, 2006, the University of Southern Alabama (USA) hired Azin Agah, a cell biologist, as a tenure-track employee, to teach biochemistry and to research the abnormalities in the extracellular matrix and angiogenesis associated with the pathogenesis of scleroderma. In 2010, USA did not reappoint Agah based on alleged research misconduct. In 2011, Agah sued several department members at the College of Allied Health Professions at USA and chairman of the two ad hoc committees that evaluated Agah, and other fictitiously named parties, alleging theft of electronic computer data and her research logbook and intentional and malicious interference with her contractual relationship with USA and seeking recovery of chattels in specie for the electronic data and her research logbook. On March 21, 2013, Agah amended her complaint adding USA and others as defendants and adding various claims. The only claim in her amended complaint that specifically named USA as a defendant "[sought] a declaratory judgment, injunctive relief, and monetary damages against USA for the breach by USA of [her] tenure track employment contract with USA." As a state school, USA argued it was immune from civil actions and petitions the Supreme Court for a writ of mandamus to direct the trial court to dismiss it from Agah's suit. Additionally, Amber Bartlett, a student who worked under Agah's supervision in USA's research laboratory and a defendant in the same underlying action, petitioned for a writ of mandamus to direct the trial court to issue an order quashing the subpoena issued to Alabama Psychiatric Services, P.C. ("APS"), ordering production of her mental-health records. The Court granted the petitions and issued the writs. USA and Bartlett have established that they had a clear, legal right to the relief they have requested. USA was entitled to absolute sovereign immunity from Agah's civil action, and the trial court was directed to enter a judgment of dismissal for USA. Bartlett was entitled to confidentiality of her mental-health records, and the trial court was directed to enter an order quashing Agah's subpoena for Bartlett's mental-health records from APS. View "Ex parte University of South Alabama" on Justia Law

In April 2010, Officer Brandon Brown, a police officer with the City of Fultondale, received a be-on-the-lookout ("BOLO") from dispatch for a blue Mitsubishi automobile, the occupants of which were suspected of having committed a theft, engaged in the pursuit of a blue Mitsubishi that he saw leaving the area of the offense. Moments after Officer Brown ceased pursuit of the blue Mitsubishi, the driver, Christopher Mitchell, ran a red light at an intersection and struck a vehicle being driven by Pamela Cupps in which David Cupps was a passenger. Pamela Cupps was killed and David Cupps was injured. David Cupps, on behalf of himself and as administrator of Pamela Cupps' estate, sued Mitchell, Officer Brown, and others. With regard to Officer Brown, David Cupps alleged that Officer Brown negligently and/or wantonly pursued Mitchell's vehicle by driving recklessly, that he negligently and/or wantonly pursued Mitchell's vehicle in violation of the City of Fultondale Police Department's pursuit policy and procedure, and that he violated section 32-5A-7(c), Ala. Code 1975, by operating his patrol vehicle in pursuit of another vehicle without the use of an audible signal. After the complaint was filed, David Cupps died; Allison Cupps, the administrator of the estates of David Cupps and Pamela Cupps, was substituted as the plaintiff. Officer Brown petitioned the Supreme Court for a writ of mandamus to direct the Jefferson Circuit Court to vacate its order denying his summary-judgment motion and to enter a summary judgment in his favor based on State-agent immunity and statutory immunity on claims filed against him by Allison Cupps. Finding that Officer Brown established, as a matter of law, that he was entitled to State-agent immunity from Cupps' action, the Supreme Court granted his petition and issued the writ. View "Ex parte Brandon Brown." on Justia Law

Dixon Mills Volunteer Fire Department, Inc. and its assistant fire chief, Louis Cass White, petitioned for a writ of mandamus to direct the Circuit Court to vacate its order denying their motion for summary judgment on the basis of immunity as to negligence claims asserted against them by plaintiffs L.C. Westbrook, Jr., and Kimberly Lewis. Plaintiffs were seriously injured when the automobile they were driving collided with a fire department truck that was dispatched to a house fire. Upon review of the circuit court record, the Supreme Court concluded that petitioners established a clear right to mandamus relief as to White, but not to the department itself. Accordingly, the Supreme Court granted the petition as to White, and directed the trial court to enter summary judgment in his favor on plaintiffs' negligence claim. The Court denied the petition as to the department. View "Ex parte Dixon Mills Volunteer Fire Department, Inc." on Justia Law

Kevin Geeslin filed this action challenging a "convenience fee" and "token fee" charged in connection with his on-line electronic filing of a civil action (fees assessed in addition to the statutorily defined filing fee that were mandated by a 2012, administrative order issued by then Chief Justice Charles Malone). That 2012 order made it mandatory for parties to file all documents in civil actions on-line, or electronically in civil actions in Alabama circuit courts and district courts by parties represented by an attorney. "AlaFile" required credit-card payment of filing fees and charges users a "convenience fee" in addition to the filing fees. Geeslin filed a putative class action naming as defendants Chief JusticevMalone in his official capacity and On-Line Information Services, Inc. ("On-Line"), the company that managed and maintained the electronic-filing system for the Alabama Administrative Office of Courts ("AOC"). Geeslin alleged that Chief Justice Malone's order was unconstitutional and that the fees collected over and above the statutorily defined filing fee amounted to an illegal tax. Geeslin sought a judgment declaring the convenience fee and another "token fee" unconstitutional and a refund of the fees paid by him and the other putative class members. The Chief Justice and On-Line moved to dismiss the complaint. The trial court granted the motion to dismiss, and Geeslin appealed. The Supreme Court affirmed the judgment of dismissal as it related to all claims against On-Line, to all claims seeking monetary relief and injunctive relief, and to the action asserted against the Chief Justice under section 1983. As to the declaratory-judgment claim against the Chief Justice, the Court reversed the trial court's judgment of dismissal and rendered a judgment in favor of Geeslin. View "Geeslin v. On-Line Information Services, Inc." on Justia Law

IBI Group, Michigan, LLC, f/k/a Giffels, LLC ("Giffels"), appealed a circuit court order ordering it to arbitrate its claims against Outokumpu Stainless USA, LLC, f/k/a ThyssenKrupp Stainless USA, LLC ("OTK"), and ThyssenKrupp Steel USA, LLC, f/k/a ThyssenKrupp Steel and Stainless USA, LLC ("TK Steel") (collectively, "the steel companies"), pursuant to an arbitration provision in the contracts at the center of this dispute. Giffels initiated this action after the steel companies commenced arbitration proceedings once it became apparent that the action the steel companies had initiated in the federal district court involving the same contract dispute would be dismissed for lack of subject-matter jurisdiction. The trial court thereafter granted the steel companies' motion to stay the action pending the completion of arbitration, and Giffels appealed, arguing that, under the circumstances, the steel companies either had no right to compel arbitration or had waived that right. The Supreme Court found that the language of the arbitration provisions in the contracts executed by the parties gave the steel companies the broad right to select arbitration as a method to resolve any disputes based on those contracts, and, because Giffels failed to demonstrate substantial prejudice as a result of the steel companies' actions, the steel companies did not waive their right to proceed in arbitration. Accordingly, the order of the trial court sending the case to arbitration and staying all proceedings pending the completion of the arbitration of the claims presented in this action was affirmed. View "IBI Group, Michigan, LLC v. Outokumpu Stainless USA, LLC" on Justia Law

Kenneth Adams appealed the grant of summary judgment in favor of Tractor & Equipment Co., Inc. ("TEC"). Adams and James "Buddy" Money are the only two members of Waste Two Energy, LLC, a company that operated two landfills in Mobile. In early 2011, Money, the managing member of Waste Two, had discussions with representatives of TEC, a company that repairs, rents, and sells heavy equipment, about servicing heavy equipment used by Waste Two in the operation of its business. Waste Two provided a "credit application and agreement" to TEC; Money and Adams were listed as the "officers, partners, or owners" of Waste Two. Money signed the agreement as the "principal of the credit applicant or a personal guarantor;" The names "James Money" and "Ken Adams" were handwritten on two lines below a guaranty provision that were each labeled "Guarantor." Beginning in March 2011 and continuing through July 2011, TEC performed various services on equipment owned by Waste Two. At some point after TEC had performed a substantial amount of work on Waste Two's equipment, a dispute arose between Waste Two and TEC over the amount of money Waste Two owed TEC for the services it had provided. Waste Two filed a complaint in the Mobile Circuit Court, asserting claims of breach of contract and misrepresentation against TEC. TEC filed a motion for summary judgment with respect to its third-party claims against Adams and Money. The court granted TEC's motion. Adams moved for reconsideration, arguing that he did not sign the guaranty to TEC, and that he should not have been held responsible in TEC's claims against Money and Waste Two. Upon review, the Supreme Court concluded that a genuine issue of material fact existed with regard to whether a valid guaranty bound Adams to TEC's alleged debt. Because an affidavit was properly before the trial court, and because the court had no basis for disregarding it, the Supreme Court held the trial court erred in entering summary judgment in favor of TEC on its breach-of-guaranty claim against Adams. View "Adams v. Tractor & Equipment Co., Inc." on Justia Law