Justia Alabama Supreme Court Opinion Summaries

AutoSource Motors, LLC petitioned the Supreme Court for a writ of mandamus to direct the Montgomery Circuit Court: (1) to vacate its order denying AutoSource's motion to dismiss the action filed against it by Stephanie Chamberlain for lack of personal jurisdiction; and (2) to enter an order granting AutoSource's motion to dismiss for lack of personal jurisdiction. The controversy arose when Chamberlain purchased a vehicle from AutoSource via the Internet. Chamberlain's affidavit did not rebut the prima facie showing made by AutoSource in that her affidavit failed to establish that AutoSource was subject to suit in Alabama pursuant to either general personal jurisdiction or specific personal jurisdiction; consequently, the Supreme Court held that the circuit court erred in denying AutoSource's motion to dismiss Chamberlain's complaint for lack of personal jurisdiction. AutoSource demonstrated a clear legal right to the relief it sought; the Supreme Court granted its petition and issued the writ. View "Chamberlain v. AutoSource Motors, LLC" on Justia Law

The State of Alabama, the Alabama Department of Finance, and the Comptroller of the State of Alabama, nonparties to the underlying action, appealed a circuit court order denying the State's motion to intervene as of right. Mrs. Frances Ann Yarbrough died intestate with no heirs that were in the line of descendant distribution. As a result, her assets escheated to the State of Alabama. The Supreme Court ordered the Estate to pay certain expenses of the Estate, and then to pay the balance of the Estate's funds to the State of Alabama. In that same order, the Court ordered the State of Alabama to pay the escheated funds to the St. Clair County's Circuit Clerk's office to be used by the Clerk 'to rehire some of the employees lost to proration.' The State, through its counsel Mr. Bledsoe, stated that the Estate's escheated funds must be used or applied in furtherance of education in accordance with the Alabama Constitution.Through counsel, Mr. Bledsoe, declared that there was no objection to disbursing the Estate's escheated assets to the Pell City Board of Education and the St. Clair County Board of Education. Based on that representation, the Estate moved the Supreme Court to Alter, Amend, or Vacate its earlier order to direct the State to pay the Estate's escheated assets to the Pell City Board of Education and the St. Clair County Board of Education. The State objected to the Supreme Court's order. In turn, the Supreme Court treated the objection as a Motion to Alter, Amend, or Vacate, filed it with the circuit clerk, and set the matter for a hearing. Because the State was not a party to this matter, the State did not receive direct notice of the hearing. The Estate's counsel, Ms. Williams, however, provided the State notice of the hearing by e-mail to Mr. Bledsoe. The State did not appear at the hearing, and the Supreme Court denied the relief requested by the State. The circuit court then denied the State's motion to intervene. Because the circuit court failed to follow the Supreme Court's order, it reversed the circuit court's order denying the State's motion to intervene. "The circuit court exceeded its authority in attempting to appropriate the escheated funds." All issues having been decided on both the motion to intervene and the underlying action, a judgment was rendered for the State. View "Alabama et al. v. Estate Yarbrough" on Justia Law

Elaine Dees sued Guyoungtech USA, Inc., alleging retaliatory discharge. A jury awarded Dees $1 million in compensatory damages and $2.5 million in punitive damages. The trial court denied Guyoungtech's post-trial motion for a judgment as a matter of law ("JML") or, alternatively, for a new trial but remitted the awards to $300,000 in compensatory damages and $900,000 in punitive damages, which Dees accepted. Guyoungtech appealed. Because the Supreme Court concluded that Guyoungtech is entitled to a new trial, it did not address the denial of its motion for a JML. View "Guyoungtech USA, Inc. v. Dees " on Justia Law

Petitioners the City of Valley Grande and its mayor, David Labbe, petitioned the Supreme Court for a writ of mandamus to direct the Circuit Court to vacate its order denying petitioners' motion for a summary judgment and to enter a summary judgment for the petitioners on claims asserted against them by Marcus Kelley, Yolanda Kelley, and Jeffery Barlow, Jr. The Valley Grande Volunteer Fire Department was incorporated specifically as a charity under 501(c)(3) of the Internal Revenue Code. In 2008, the City entered into an agreement with the fire department to which the fire department agreed to provide fire protection service to the City "without remuneration." However, the petitioners did acknowledge in the fire-service agreement that the City "ha[d] in the past and likely [would] continue to provide [the fire department] with some level of annual funding." Mayor Labbe testified that the City and the fire department are separate entities and that the City did not maintain or reserve any right of control over the fire department. In early 2011, James Barlow, Sr., and his mother, Bertha Yeager, were killed in a house fire. W. Alan Dailey, the coroner for Dallas County, pronounced Barlow and Yeager dead at the scene and directed members of the fire department to remove the remains of the deceased from the house. The plaintiffs alleged that the fire department represented that it had recovered all the decedents' remains. The plaintiffs stated that in April 2011 the family discovered a body bag at the scene of the fire that contained additional remains of Barlow. Plaintiffs sued petitioners, among others, asserting claims of negligence; wantonness; intentional infliction of emotional distress; fraud; suppression; and negligent and/or wanton hiring, training, and supervision of the individual firefighters against both the City and the mayor. Petitioners moved for a summary judgment, arguing, among other things, that the petitioners did not employ, supervise, or train any firefighters; that petitioners did not reserve any right of control over the fire department; that the petitioners were entitled to immunity pursuant to the Volunteer Service Act, 6-5-336, Ala. Code 1975; that the City was immune from suit for intentional torts of its agents, officers, or employees; and that the petitioners could not be liable for negligent and/or wanton hiring, training, or supervision of the individual firefighters because, they said, no master-servant relationship existed between the City and the fire department. The trial court denied petitioners' motion. Because of the procedural posture of this case, the Supreme Court addressed only those issues on immunity grounds and concluded that the agreement between the City and the fire department, as well as the donations made to the fire department by the City, did not alter the fire department's status as a "volunteer" fire department. Furthermore, the Court concluded that the firefighters were immune from liability for their negligent acts under the Volunteer Service Act. Accordingly, the Court granted the petition for a writ of mandamus in this case and directed the trial court to enter summary judgment for the petitioners. View "Kelley et al. v. Dailey" on Justia Law

Chase Andrew Dunn petitioned the Supreme Court for certiorari review of the Court of Criminal Appeals' decision affirming the trial court's revocation of his probation. Dunn pleaded guilty to first-degree assault, and was sentenced to 10 years' imprisonment. That sentence was split, and Dunn was ordered to serve two years' imprisonment followed by three years' probation. Dunn's probation officer filed a delinquency report alleging that Dunn had violated the terms of his probation by: (1) committing the new offense of third-degree robbery; (2) failing to pay court-ordered moneys; and (3) failing to pay supervision fees. The Supreme Court granted Dunn's petition to determine whether the Court of Criminal Appeals' decision conflicted with "Goodgain v. Alabama," (775 So. 2d 591 (Ala. Crim. App. 1999)). The Supreme Court concluded that it did, and therefore reversed and remanded the case for further proceedings. View "Dunn v. Alabama" on Justia Law

Merchants Bank appealed a Circuit Court judgment in favor of Elizabeth Head on Merchants Bank's claim against her alleging breach of a promissory note. After the 2008 promissory note at issue was executed, Merchants Bank wired the $400,000 to Elizabeth's husband, David Head's, personal account. David testified that he then wrote a check distributing the funds to his real-estate-development company, Head Companies, LLC. The Heads renewed the 2008 promissory note in March 2009 and again in March 2010, in August 2010, in February 2011, and, finally, in July 2011. With the exception of the July 2011 renewal, each renewal was signed on page three by both David and Elizabeth. A box on page two was left blank. On the initial version of the July 2011 renewal of the note, however, Elizabeth signed in both the box on page two, indicating that she intended to "give [Merchants Bank] a security interest" in the Heads' personal residence, and at the end of the document on page three. signature on page two of the initial July 2011 note was "a mistake in the nature of a scrivener's error and [Merchants] Bank subsequently had the Heads execute a corrected note, which they did knowingly and voluntarily." Elizabeth presented no evidence to the contrary. The "corrected note" bore the same date as the initial July 2011 note and, like all the previous renewals, was signed by both David and Elizabeth on page three of the document only. The box on page two of the corrected July 2011 note was left blank. The Heads defaulted on the promissory note in April 2012. In September 2012, Merchants Bank sued the Heads, alleging breach of the promissory note and attaching to the complaint the initial July 2011 note as evidence of the debt. David did not answer the complaint, and Merchants Bank obtained a default judgment against him in the amount of $415,142.57 plus interest on the judgment. Elizabeth did answer the complaint, arguing that the note was unenforceable against her because she had signed the initial July 2011 note only to give a security interest in her and David's residence not "for the purpose of agreeing to pay the debt evidenced thereby" and because she had not received consideration for her signature on the note. Merchants Bank moved for a summary judgment against Elizabeth. That motion was denied. After a bench trial in March 2013, the circuit court entered a final judgment in favor of Elizabeth. Upon review, the Supreme Court held that Elizabeth renewed her obligations under the 2008 promissory note in the capacity of a maker in July 2011, and that her obligations under the 2008 promissory note were supported by valid consideration. It was undisputed that she and David defaulted on their obligations under the corrected July 2011 note. Thus, Elizabeth was liable to Merchants Bank on its claim of breach of promissory note, and the circuit court erred in entering a judgment in her favor. View "Merchants Bank v. Head " on Justia Law

R.C.W. was convicted of first-degree rape, first-degree sexual abuse, and two counts of first-degree sodomy. The trial court sentenced R.C.W., pursuant to the Habitual Felony Offender Act, to life imprisonment on the incest and first-degree-sexual-abuse convictions and to life imprisonment without the possibility of parole on the first-degree rape and both first-degree-sodomy convictions. The Court of Criminal Appeals reversed R.C.W.'s convictions in a 3 to 2 decision. The Supreme Court granted the State's petition for a writ of certiorari to determine, as a matter of first impression, whether an erroneous limiting instruction, as to otherwise properly admitted Rule 404(b) collateral-acts evidence, was subject to a harmless-error analysis. In this matter, the Court agreed with the Court of Criminal Appeals that the evidence relating to R.C.W.'s prior sexual misconduct with his daughters was admissible to show motive. Furthermore, the Court agreed that the trial court's limiting instruction was erroneous because it permitted the jury to consider the collateral-acts evidence for issues not in dispute. The Court applied a harmless-error analysis and concluded that any error arising from the trial court's limiting instruction was harmless and was not prejudicial to R.C.W. Accordingly, the judgment of the Court of Criminal Appeals was reversed, and the case remanded for further proceedings. View "R. C. W. v. Alabama" on Justia Law

Mary Leila Beasley Schaeffer and the estate of Emma Glass Beasley appealed a judgment entered on a jury verdict awarding compensatory damages and punitive damages on mismanagement-of-trust and conversion claims in an action by William Poellnitz, as administrator of the estate of Edwin Glass Young, Adele Young Sommers, and Willard Young. The Beasleys raised five issues on appeal: (1) it was entitled to a judgment as a matter of law (JML) on the mismanagement-of-trust claim; (2) it was entitled to a JML on the conversion claim; (3) punitive damages were not warranted, or in the alternative, the trial court improperly apportioned the punitive damages and that they were excessive and must be vacated or remitted; (4) it was entitled to a JML on the Youngs claim to a one-half ownership interest in the furnishings and heirlooms from the estate or to a reduction of the value of those furnishings and heirlooms; and (5) it was entitled to a JML on all of its counterclaims for moneys loaned to the Youngs. Upon review of the matter, the Supreme Court concluded the trial court erred in denying the Beasleys motions for a JML as to the mismanagement-of-trust claim. The Court also reversed the award of punitive damages with respect to that claim. The trial court also erred in denying the motion for a JML filed by Emma's estate as to the conversion claim. The Court affirmed as to the conversion claim against Mary, including the amount of the compensatory damages awarded the Youngs on that claim. However, because there was no clear and convincing evidence that Mary "consciously and deliberately engaged in oppression, fraud, wantonness, or malice," the Court reversed the trial court's judgment insofar as it awarded punitive damages on the conversion claim against Mary, as well as against Emma's estate. The Court affirmed the judgment as to the Young branch's one-half interest in the furnishings and heirlooms in the house and on the Beasleys counterclaims for money loaned. View "Beasley v. Poellnitz" on Justia Law

James Sheffield was indicted on two counts of reckless murder for intentionally setting fire to a cushion he had placed underneath a house that caused a house to catch fire, killing two persons inside the house. Sheffield was convicted of reckless murder on count I (for the death of Charles Morrow, Jr.) and of the lesser-included offense of manslaughter on count II (the death of Charles Morrow III). He was sentenced to 50 years in prison on the reckless murder conviction and to 17 years on the manslaughter conviction, the sentences to run consecutively. Sheffield appealed. On appeal, the Court of Criminal Appeals affirmed the manslaughter conviction on count II but reversed the reckless murder conviction on count I and remanded the case for the circuit court to enter a judgment finding Sheffield guilty of manslaughter on count I and to resentence Sheffield accordingly. On remand, the circuit court entered a judgment convicting Sheffield of manslaughter as to count I. The circuit court then sentenced Sheffield to 17 years' imprisonment for his conviction on count I, the sentence to run consecutively to Sheffield's 17-year sentence on his count II manslaughter conviction. Sheffield appealed again, challenging the sentencing order and contending that the circuit court erred when it imposed consecutive sentences for multiple convictions arising out of a single act. The Court of Criminal Appeals dismissed the appeal on the basis that it lacked jurisdiction to hear an appeal from a sentencing order such as the one at issue here. Sheffield contended on appeal to the Supreme Court, and the State agreed, that the Court of Criminal Appeals had jurisdiction to consider Sheffield's appeal challenging the new sentence imposed by the circuit court on remand. The Supreme Court also agreed, reversed the appellate court and remanded the case for further proceedings. View "Sheffield v. Alabama " on Justia Law

In 2008, a grand jury charged Lam Luong with five counts of capital murder in connection with the deaths of his four children. He was later convicted on all counts, for which he received a death sentence. The Court of Criminal Appeals reversed Luong's convictions and death sentence, holding that the trial court erred by refusing to move the trial from Mobile County because, it reasoned, the pretrial publicity was presumptively prejudicial and by refusing to conduct individual questioning of the potential jurors regarding their exposure to that publicity. The Court of Criminal Appeals also held that the trial court erred in denying defense counsel funds to travel to Vietnam to investigate mitigation evidence and in admitting into evidence during the sentencing hearing a videotape simulation using sandbags approximately the weight of each child illustrating the length of time it took for each child to fall from the bridge to the water. The Supreme Court found that the trial court did not abuse its discretion in the decisions it made in this case. As such, the Court reversed the Court of Appeals and remanded this case for further proceedings. View "Luong v. Alabama" on Justia Law