Justia Alabama Supreme Court Opinion Summaries

Consolidated appellate proceedings involved a dispute between the trustees and beneficiaries of the Bellingrath-Morse Foundation Trust ("the Trust"). In appellate case no. SC-2023-0001, beneficiaries of the Trust, Rhodes College, Huntingdon College, and Stillman College, petitioned the Alabama Supreme Court for a writ of mandamus directing the circuit court Court to vacate its November 23, 2022, order granting the trustees of the Trust relief from a final judgment pursuant to Rule 60 (b)(5), Ala.R.Civ.P. In appellate case no. SC-2023-0011, the beneficiaries appealed the same circuit-court order granting Rule 60(b)(5) relief to the trustees. Walter Bellingrath (deceased) established the charitable Trust in 1950. Bellingrath contributed to the Trust, including the Bellingrath Gardens ("the Gardens"). The trustees and beneficiaries disagreed as to whether the Trust indenture contemplated a subsidy of the Gardens by the Trust: the trustees believed the Gardens were a "purpose" of the Trust requiring perpetual funding; the beneficiaries believed the Gardens were merely an asset of the Trust and subject to closure if not profitable. A 1981 agreement limited the payments or distributions by the Trust for the support of the Gardens. In a 2003 amendment to the 1981 agreement, the beneficiaries gave up their right to request the trustees seek court instructions concerning whether the Gardens should be open or not, and the trustees agreed that they would not increase the payments for the support of the Gardens above 20% of the total annual distribution amount without the unanimous consent of the beneficiaries. In 2017, the trustees contended their ability to maintain the Gardens had been substantially impaired by the funding restraints of the 1981 agreement and the 2003 amendment, and they sought instructions on how the existing funding agreement regarding the Gardens should be revised. After the Alabama Supreme Court released its opinion in "Ex parte Huntingdon College," the trustees immediately moved the circuit court seeking relief from the 2003 judgment pursuant to Rule 60(b)(5), alleging that new circumstances had arisen since the 2003 judgment was entered, rendering prospective application of the 2003 judgment inequitable. In appellate case no. SC-2023-0001, the Alabama Supreme Court concluded the beneficiaries demonstrated a clear legal right to a writ of mandamus directing the circuit court to vacate its November 2022, Rule 60(b) order. In appellate case no. SC-2023-0011, the Court dismissed the appeal filed by the beneficiaries concerning that same order. View "Ex parte Huntingdon College, et al." on Justia Law

Consolidated appeals stemmed from an employment dispute between Dr. Margot G. Potter and her former employer, Women's Care Specialists, P.C. ("Women's Care"), and out of a dispute between Potter and three Women's Care employees: Dr. Karla Kennedy, Dr. Elizabeth Barron, and Beth Ann Dorsett ("the WC employees"). In case no. CV-21-903797, Potter alleged claims of defamation, tortious interference with a business relationship, and breach of contract against Women's Care. In case no. CV-21-903798, Potter alleged claims of defamation and tortious interference with a business relationship against the WC employees. After the trial court consolidated the cases, Women's Care and the WC employees filed motions to compel arbitration on the basis that Potter's claims were within the scope of the arbitration provision in Potter's employment agreement with Women's Care and that the arbitration provision governed their disputes even though Potter was no longer a Women's Care employee. The trial court entered an order denying those motions. Women's Care and the WC employees separately appealed; the Alabama Supreme Court consolidated the appeals. In appeal no. SC-2022-0706, the Supreme Court held that Potter's breach of-contract claim and her tort claims against Women's Care were subject to arbitration. The Court therefore reversed the trial court's order denying Women's Care's motion to compel arbitration. In appeal no. SC-2022-0707, the Supreme Court held that Potter's tort claims against the WC employees were subject to arbitration. The Court therefore reversed the trial court's order denying their motion to compel arbitration, and remanded both cases for further proceedings. View "Women's Care Specialists, P.C. v. Potter" on Justia Law

Gary and Sheila Womble, a married couple, appealed a circuit court order denying their motion filed pursuant to Rule 60(b)(1), Ala. R. Civ. P., seeking to set aside a judgment that dismissed, with prejudice, their action against Collie Moore III. In 2020, the Wombles sued Moore alleging claims of negligence, wantonness, and loss of consortium in connection with an automobile accident that had occurred March 28, 2018, in which Moore's automobile collided with the rear of the Wombles' automobile. The Alabama Supreme Court determined the Wombles did not demonstrate that the trial court exceeded its discretion in denying their Rule 60(b)(1) motion; therefore, it affirmed the trial court's order denying their motion. View "Womble v. Moore" on Justia Law

Andrew William Spraggins's driveway crossed a neighboring tract of land owned by Ammons Properties, LLC ("Ammons"). After a dispute arose between Spraggins and Ammons, Spraggins filed a complaint asking a circuit court to enter a judgment declaring that he had an easement for the portion of his driveway that crossed Ammons's property. Ammons filed a counterclaim alleging that Spraggins was liable for several tortious acts. Following a bench trial, the circuit court ruled that Spraggins had an easement across Ammons's property and denied Ammons's counterclaims. Ammons appealed. Finding no reversible error, the Alabama Supreme Court affirmed the trial court's judgment. View "Ammons Properties, LLC v. Spraggins" on Justia Law

The property at issue in this appeal served as a rental home located in a residential neighborhood. The property owner, J.C. King III, stopped paying property taxes in 2015 after a fire extensively damaged the property and rendered it uninhabitable. The State of Alabama purchased the property at a 2016 tax sale, and in 2019 the property was ultimately sold in its uninhabitable state to Anderson Realty Group, LLC ("ARG"). ARG spent $88,812 to extensively renovate and restore the property to a habitable condition, and in 2020 it filed a complaint seeking to quiet title to the property. King filed a counterclaim to redeem the property and disputed whether the extensive renovations to the property could be considered "preservation improvements" due to be included in the redemption amount pursuant to § 40-10-122, Ala. Code 1975. The trial court agreed with King, holding that "preservation improvements" included only those amounts expended by ARG to keep the property from further deterioration, the value of which it concluded was $10,000, and it entered a judgment setting the redemption amount accordingly. ARG appealed, and the Court of Civil Appeals reversed that judgment, holding that the trial court had erred in limiting the "preservation improvements" to the cost of repairs undertaken to keep the property in the same condition it was in at the time of the tax sale. The Alabama Supreme Court granted King's petition for a writ of certiorari to consider, as a matter of first impression, the meaning of the phrase "preservation improvements" as defined in § 40-10-122(d). The Supreme Court agreed that the trial court erred in limiting ARG to the recovery of the cost of repairs to keep the property in the same condition it was in at the time of the tax sale. Accordingly, its judgment was affirmed. View "Ex parte J.C. King III" on Justia Law

Midsouth Paving, Inc. ("Midsouth"), and Christopher Nivert petitioned the Alabama Supreme Court for a writ of mandamus directing the Tallapoosa Circuit Court ("the trial court") to enter a summary judgment in their favor in an action commenced against them by Yvonne Mason. Mason worked for PeopleReady, a temporary staffing agency, at Midsouth jobsites. PeopleReady initially provided Mason with a hard hat, sunblock, water, and a vest with "Midsouth" printed on it, and Mason kept those items in her automobile. At the job site, Midsouth employees directed and supervised Mason's job duties. Mason was working at a Midsouth job site when Nivert unintentionally drove his pilot vehicle into Mason while he was making a three-point turn. Mason's leg was severely injured, and she received multiple surgeries and remained in a hospital and then a rehabilitation facility for over a month. PeopleReady began paying workers' compensation benefits to Mason after the accident and also paid or her continued medical care. Pursuant to the labor-supply agreement, Midsouth was an insured alternate employer under PeopleReady's workers' compensation insurance policy. Mason also filed the underlying lawsuit alleging claims of negligence; wantonness; negligent hiring, training, and supervision; and negligence per se. Midsouth's motion for summary judgment was denied, leading to the mandamus relief requested in this case. After careful consideration, the Supreme Court found Mason's claims against Midsouth and Nivert were barred by § 25-5-11, § 25-5-52, and § 25-5-53, Ala. Code 1975, of the Alabama Workers' Compensation Act ("the Act"), § 25-5-1 et seq., Ala. Code 1975. Accordingly, the Supreme Court granted the petition and directed the trial court to enter a summary judgment in favor of Midsouth and Nivert. View "Ex parte Midsouth Paving, Inc., et al." on Justia Law

MUSA Properties, LLC ("MUSA"), and R.K. Allen Oil Co., Inc. ("Allen Oil"), entered into a real-estate sales contract in which MUSA agreed to purchase from Allen Oil a gasoline service station and convenience store ("the property"). The terms of the sales contract were not fulfilled, and the property was not transferred to MUSA. Allen Oil filed a lawsuit against MUSA, alleging various causes of action based on the sales contract; MUSA filed various counterclaims in response. MUSA also filed in probate court a notice of lis pendens describing the property. In an interlocutory order, the circuit court later determined that MUSA did not have a right to or interest in the property, and, upon the motion of Allen Oil, the circuit court entered an order expunging the lis pendens notice. MUSA then petitioned the Alabama Supreme Court for mandamus relief, to direct the circuit court to vacate its order expunging the lis pendens notice. Finding that Allen Oil's argument did not provide a convincing basis for the Supreme Court to suspend application of the doctrine of lis pendens and deny MUSA's mandamus petition, the Court granted the petition and issued the writ directing the circuit court to vacate its order expunging the lis pendens notice. View "Ex parte MUSA Properties, LLC" on Justia Law

The Ohio Valley Conference ("the OVC") appealed a judgment dismissing its official-capacity and individual-capacity claims against Randall Jones, the Chair of the Board of Trustees of Jacksonville State University ("JSU"), and Don C. Killingsworth, Jr., the President of Jacksonville State University. The OVC was a men's and women's collegiate athletic conference that began in 1948. The OVC Constitution contained two relevant provisions concerning resignation of membership from the conference. In addition to alleging that JSU had failed to pay the conference-resignation fee described in Article 4.5.3 of the OVC Constitution, the OVC also asserted that JSU owed the conference money for tickets to certain conference championship basketball tournament tickets. JSU, Jones, and Killingsworth filed a joint motion to dismiss the OVC's complaint. With respect to the OVC's claims against JSU, defendants argued that the Alabama State Board of Adjustment ("the BOA") had "exclusive jurisdiction" over those claims. With respect to any claims the OVC asserted against Jones and Killingsworth in their official capacities, defendants argued the claims were barred by State immunity under § 14 of the Alabama Constitution. With respect to any claims the OVC asserted against Jones and Killingsworth in their individual capacities, defendants argued the OVC had failed to state a claim upon which relief could be granted, and they maintained that the claims were barred by the doctrine of State-agent immunity. The Alabama Supreme Court concluded the OVC's claims against Jones and Killingsworth in their official capacities seeking payment for the liquidated amount of the conference-resignation fee and for the value of the tickets JSU received for the OVC's 2021 conference championship basketball tournament did not constitute claims against the State, and, therefore, they were not barred by State immunity. Accordingly, the circuit court erred in dismissing the OVC's official-capacity claims against Jones and Killingsworth. However, the Court found the OVC failed to state individual-capacity claims against Jones and Killingsworth for which relief could be granted because Jones and Killingsworth lacked any duty apart from their official positions to make the payments the OVC sought to recover and because the OVC's complaint did not supply the factual allegations necessary to support those individual-capacity claims. View "Ohio Valley Conference v. Jones, et al." on Justia Law

Douglas Byrne appealed the grant of summary judgment in favor of Vera Fisk regarding Byrne's premises-liability negligence claim against Fisk. In December 2018, Byrne was a mail carrier working for the United States Postal Service. That evening, Byrne was responsible for a delivery route different from his usual route. Byrne attempted to deliver mail to Fisk's residence in Huntsville. Although Fisk's home was not on his usual delivery route, Byrne had likely delivered mail there before, including within the preceding year. It was dark outside, and it was raining. Fisk's porch lights were not turned on, but Byrne was wearing a headlamp, which was on at the time. Byrne was also wearing slip- resistant boots, as required by his employer. Byrne traversed the five tiled steps leading to Fisk's tiled front porch, where her mailbox was located. According to Byrne's testimony, he was holding the handrail and being careful. However, Byrne slipped and fell backward down the steps. Byrne suffered three fractures in his right femur and a fracture in his hip socket. He was hospitalized for nine days, underwent multiple weeks of rehabilitation, and returned to work in May 2019. In December 2020, Byrne commenced this action against Fisk and fictitiously named parties. Byrne alleged that there were defects in Fisk's premises about which Fisk knew or should have known and that Fisk should have remedied the defects or should have warned him about or guarded him from the defects. Byrne's complaint asserted a negligence claim and a "wantonness/recklessness" claim. The Alabama Supreme Court concluded genuine issues of material fact existed regarding whether a defect or unreasonably dangerous condition existed on Fisk's premises; whether Fisk had knowledge of the alleged defect; whether the alleged defect proximately caused Byrne's injuries; and whether the darkness of Fisk's premises or the rainfall present there constituted open and obvious hazards. Consequently, the circuit court erred by entering a summary judgment in favor of Fisk. Judgment was reversed and the matter remanded for further proceedings. View "Byrne v. Fisk" on Justia Law

Debbie Berry appealed a circuit court's grant of summary judgment in favor of PHH Mortgage Corporation ("PHH") on PHH's ejectment claim and Berry's breach-of-contract counterclaim. The Alabama Supreme Court affirmed the judgment because Berry waived most of the arguments she raised on appeal by failing to address the effects of her prior settlement with PHH's predecessor and because her other appellate arguments failed to demonstrate that the circuit court erred. View "Berry v. PHH Mortgage Corporation" on Justia Law