Justia Alabama Supreme Court Opinion Summaries

Raymond James Financial Services, Inc. (RJFS), and its employee, Bernard Michaud appealed a trial court order vacating an arbitration award in their favor and entering a judgment in favor of Kathryn Honea. Honea had multiple investment accounts with Raymond James and sued RJFS alleging violations of the Alabama Securities Act and sought damages for breach of contract, breach of fiduciary duty, negligence, wantonness, and fraud. RJFS moved to compel arbitration, and the trial court granted the motion. An arbitration panel unanimously entered an award in favor of RJFS on Honea's claims. Honea filed a motion at circuit court to vacate the award. The trial court ultimately vacated the award, and RJFS appealed. On appeal, the Supreme Court reversed the trial court's judgment vacating the arbitration award, holding that a provision in the arbitration agreement Honea signed when she opened the accounts required the trial court to conduct a de novo review of the arbitration award, and remanded the case for it to conduct such a review. Both parties acknowledged on appeal that the award had not been entered as a judgment of the trial court. Because the award to RJFS was not entered as a judgment of the trial court as required by statute, the Supreme Court could reach no other conclusion but that the trial court lacked subject-matter jurisdiction to review the award on remand. Accordingly, the trial court's judgment purporting to vacate that award and to enter a judgment in favor of Honea was void. This appeal was dismissed. View "Raymond James Financial Services, Inc. v. Honea " on Justia Law

AltaPointe Health Systems, Inc. ("AHS"), appealed a probate court order denying its petition for an award of expert-witness fees a civil-commitment proceeding. This case presented a matter of first impression for the Supreme Court. By disqualifying AHS from receiving expert-witness fees for the testimony of its employees, the Supreme Court concluded the Probate Court erred as a matter of law. When the probate court elicits testimony from an expert witness provided by AHS on the issue of civil commitment and the witness is an employee of AHS, a plain reading of section 22-52-14 entitles AHS to such fees as the probate court in its discretion determines are reasonable. View "AltaPointe Health Systems, Inc. v. Mobile County Probate Court " on Justia Law

Donald Hughes and John Hughes appealed circuit court judgment vacating a deed and imposing a constructive trust upon real property formerly owned by Henry Hughes and Emma Lucille Hughes, both of whom are deceased. Because the Supreme Court concluded that the circuit court never acquired jurisdiction of the claim at issue, it vacated the judgment and dismissed the appeal. View "Hughes v. Robbie Branton " on Justia Law

Ann Whitty, Tratillia McCall, and other class-action plaintiffs filed suit against Montgomery County and Janet Buskey (in her capacity as Montgomery County Revenue Commissioner. Plaintiffs appealed the dismissal of their case by the Montgomery Circuit Court. Whitty and McCall, on behalf of themselves and a purported class of similarly situated property owners, filed suit seeking class certification of Montgomery County property owners whose properties were sold because of delinquent ad valorem taxes, where the sales produced an excess over the taxes, interest, penalties and costs due. Following discovery, a question of standing arose with regard to the class representatives. The County and the revenue commissioner moved to dismiss and/or to strike amended complaints, arguing that Whitty and McCall lacked "standing" to pursue the claims in their original complaint and, therefore, that the trial court lacked subject-matter jurisdiction over the action at its outset. Upon review, the Supreme Court affirmed the trial court's dismissal of the complaint insofar as it related to the claims alleged by Whitty and McCall. However the Court reversed the trial court's judgment insofar as it included a dismissal of the claims of the additional plaintiffs added by amendments to the original complaint. The trial court was not without subject-matter jurisdiction over claims originally alleged by McCall; therefore, the various amendments to the complaint adding additional plaintiffs were viable. View "Whitty et al. v. Montgomery County et al. " on Justia Law

In 2004, the Baldwin County Commission passed a resolution recognizing the Fair Association's planned construction of a multimillion dollar coliseum at the Association's new fairgrounds site in Baldwin County. The Commission resolved to provide long-term funding for the Fair Association for a period of 10 years, beginning in the County's 2005 fiscal year. In 2008, the County and the Fair Association entered into a real-estate sale and purchase agreement for the conveyance of the coliseum property to the County. The purchase agreement provided that the County would be "released and relieved from paying [the Fair Association]the Seventy Five Thousand Dollars ($75,000.00), annual payment...." Following conveyance of the coliseum property, the parties entered into a lease agreement for the property. Despite the parties' agreement to discontinue the annual $75,000 payment to the Fair Association, the County made two additional payments in 2009 and in 2010. Each additional payment was presented to the County Commission as part of the "County Commission Accounts Payable Payments" and approved by the Commission along with payments to other vendors. The County asserted the two payments were made by mistake and sued the Association to recover the payments. After a hearing on the matter, the circuit court granted the Fair Association's motion for a judgment on the pleadings. The County appealed. Finding no reversible error, the Supreme Court affirmed the circuit court's judgment. View "Baldwin County v. Baldwin County Cattle & Fair Association, Inc. " on Justia Law

The Water Works and Sewer Board of the City of Prichard appealed the grant of summary judgment in favor of the Board of Water and Sewer Commissioners of the City of Mobile d/b/a Mobile Area Water and Sewer Service System in a declaratory and injunctive relief action. The dispute centered on the Mobile Water Board's planned takeover of the water and sewer systems currently being operated by the Prichard Water Board. "Because Amendment No. 863 affected only Mobile County, the legislature should have followed the procedure in section 284.01 instead of the procedure in section 284, and that noncompliance with 284.01 invalidated Amendment No. 863 in spite of any compliance with section 284." The Supreme Court reversed and remanded. The Supreme Court did not address all other arguments raised by the parties, and remanded the case for further proceedings. View "The Water Works & Sewer Board of the City of Prichard v. The Board of Water & Sewer Commissioners of the city of Mobile" on Justia Law

The Supreme Court consolidated two cases for the purposes of this opinion. Each of the plaintiffs in these cases attended a foreclosure auction, was the successful bidder at that auction, paid money for the auctioned property, and received a foreclosure deed to the property. Each plaintiff brought an ejectment action under Alabama law, claiming good title to the property at issue and the right to eject the original debtor. Upon review, the Supreme Court concluded that the trial courts had subject-matter jurisdiction over these cases, including any issue as to the validity in fact of the plaintiffs' title to the property (this being one of the elements of proof required in an ejectment action). The Supreme Court reversed the trial court in the "Strudivant" case, but affirmed in the "Harris" case. View "Sturdivant v. BAC Home Loans Servicing, LP" on Justia Law

General Motors of Canada Limited ("GM Canada") petitioned the Supreme Court for a writ of mandamus to direct the Choctaw Circuit Court to enter a summary judgment in its favor on the ground that the plaintiff's substitution of GM Canada for a fictitiously named defendant was made after the expiration of the applicable statute of limitations and does not relate back to the filing of the original petition. Upon review of the matter, the Supreme Court concluded GM Canada met the requirements for the issuance of the writ. The Court granted the petition and issued the writ. View "Poole v. General Motors Corporation et al." on Justia Law

GMAC Mortgage, LLC challenged the reversal of a circuit court judgment entered on GMAC Mortgage's ejectment action against Reginald and Diana Patterson. Upon review the Supreme Court reversed the appellate court's and remanded for further proceedings: "We … recognize, contrary to the holding of the Court of Civil Appeals, that, with respect to nonjudicial foreclosures through the exercise of a power of sale, there is no 'initiation of foreclosure proceedings' with the import ascribed to it. Nor does a 'foreclosure' of the mortgagor's rights occur at some midpoint in that process. We are left then with the notion, long established as it turns out, that the 'foreclosure' of a mortgagor's rights does not occur until the 'end,' when a deed divesting the mortgagor of its rights is signed and delivered to a purchaser." View "Patterson v. GMAC Mortgage, LLC " on Justia Law

In petitions for a writ of mandamus, two juvenile offenders sought dismissal of capital-murder indictments based on "Roper v. Simmons," (543 U.S. 551 (2005)), and "Miller v. Alabama," (132 S.Ct. 2455 (2012)). Both juveniles argued that Alabama's capital-murder statute was unconstitutional as applied to them because the mandatory sentencing structure provides that all defendants charged with a capital offense, including juveniles, must receive either a sentence of death or a mandatory sentence of life imprisonment without parole. Upon review, the Supreme Court concluded the juveniles failed to show that the holding in Miller required it to dismiss the capital-murder indictments against them. Accordingly, their petitions for a writ of mandamus were denied. View "Alabama vs. Henderson " on Justia Law