Justia Alabama Supreme Court Opinion Summaries

Defendant Alabama Power Company filed a petition for the writ of mandamus to ask the Supreme Court to direct the trial court to dismiss Plaintiff Capitol Container, Inc.'s claims against it for lack of subject-matter jurisdiction. On appeal, Alabama Power argued the Alabama Public Service Commission (APSC) had exclusive jurisdiction over those claims Capitol filed, and Capitol failed to exhaust its administrative remedies before filing its action. Upon review of the record below, the Supreme Court found that Capitol indeed failed to exhaust its administrative remedies before filing its suit against the power company. The Court issued the writ. View "Capitol Container, Inc. v. Alabama Power Co." on Justia Law

Plaintiff Jerry Elliott sought workers' compensation benefits from his employer, International Paper Company, Inc. (IP). He petitioned the Supreme Court for a writ of mandamus to quash a Court of Civil Appeals' writ of mandamus directed to the Conecuh Circuit Court. Plaintiff lived in Conecuh County for over 15 years and for 21 years worked as a machine operator at the plywood-manufacturing plant owned by IP located in Butler County. In 2007, he allegedly sustained an injury to his shoulder while at work. He filed an action at the Conecuh Circuit Court seeking workers' compensation benefits. IP filed motions to dismiss Plaintiff's action or, in the alternative, to transfer the case to Butler County. After a hearing, the trial court denied the motions to dismiss or to transfer. IP then filed a petition for the writ of mandamus at the Court of Civil Appeals to review the trial court's denial of its motion. The Court of Appeals granted the writ directing the Conecuh Court to transfer the case to Butler County. Upon review, the Supreme Court concluded the appellate court's decision was in error, and quashed the writ that was issued transferring venue to Butler County. View "Elliott v. International Paper Co., Inc." on Justia Law

The Supreme Court granted the State's petition for a writ of certiorari to address whether an indigent defendant, who has no right to initially choose a particular court-appointed attorney, had a right to continued representation by a particular court-appointed counsel. The Court of Criminal Appeals held that an indigent defendant had such a right. The Supreme Court granted the petition and issued the writ because the trial court, when it considered the State's motion, did not evaluate the evidence regarding the question of disqualification and did not weigh the constitutional rights at issue. Upon review of the applicable legal authority and the record of Defendant Thomas Lane's case, the Supreme Court concluded "an indigent defendant is not entitled to legal counsel of his choice, when counsel is to be paid by public funds, but rather is entitled to competent legal representation." The Court reversed the appellate court and remanded the case for further proceedings. View "Lane v. Alabama" on Justia Law

Branson Machinery, LLC appealed a circuit court's decision that set aside a default judgment granted in its favor against Hilltop Tractor, LLC and Jeffrey Williams. According to Branson, Hilltop owed it money for equipment it had purchased. Because it had not received payment, Branson filed a breach-of-contract action against Hilltop and Mr. Williams. The Blount Circuit Court entered a default judgment in favor of Branson. Following the entry of the default judgment, Branson's counsel engaged Hilltop and Mr. Williams (acting without counsel) in settlement negotiations. The parties negotiated a "workout" agreement, and at some point, Hilltop became unable to meet the payment terms. Branson filed garnishment paperwork with the trial court seeking to enforce the original default judgment. Hilltop and Mr. Williams hired counsel and successfully moved the court to set aside the default judgment. Upon review, the Supreme Court found that the trial court exceeded its discretion in granting Hilltop and Mr. Williams' motion to set aside the default judgment. The Court reversed the trial court's decision and remanded the case to reinstate the original default judgment. View "Branson Machinery, LLC v. Hilltop Tractor, LLC" on Justia Law

The Industrial Development Board of the City of Montgomery (IDB) appealed a circuit court's interlocutory order that denied its motion for summary judgment as to a breach-of-contract claim asserted against it by George and Thomas Russell as co-executors and co-trustees of the wills and testamentary trusts of Earnest and Myrtis Russell, Price and Mary McLemore and several others. In 2001, various officials of the State of Alabama, the City of Montgomery, the Montgomery County Commission, Montgomery Chamber of Commerce and the local water works board began making preparations to secure options to purchase property in the Montgomery area in an attempt to persuade Hyundai Motor Company to build an automobile plant in the area. All the trusts owned acres of land in the targeted area. The IDB signed separate options with the Russells, the McLemores and other trusts to purchase the respective properties. Hyundai's plans for its manufacturing plant changed, and subsequently, not all of the options were exercised. The Russells and the McLemores each filed breach-of-contract actions against the IDB and Hyundai alleging that neither adhered to the terms of their respective options. Upon review, the Supreme Court found that the trial court did not err in denying the IDB's motion for summary judgment. The Court affirmed the lower court's decision. View "Indust. Develop. Bd. of the City of Montgomery v. Russell" on Justia Law

Two appeals between MPQ, Inc. (d/b/a Freedom Enterprises) and Birmingham Realty Company were consolidated by the Supreme Court for the purposes of this opinion. The parties entered into a commercial lease agreement. Birmingham Realty filed suit against MPQ for unpaid rent in circuit court. MPQ filed a counterclaim. Birmingham Realty filed a separate unlawful-detainer action against MPQ in district court. The district court dismissed the detainer action, reasoning that the simultaneous actions in the district and circuit courts violated Alabama's abatement statute. Birmingham Realty appealed the district court's dismissal to the circuit court and filed a motion to dismiss MPQ's counterclaim. The circuit court conducted a hearing on all pending motions. It then entered an order affirming the district court's dismissal of the unlawful-detainer action and dismissed MPQ's counterclaims in the rent action. The court suggested that Birmingham Realty move to dismiss the rent action without prejudice so it could refile its unlawful-detainer action in the district court and then later refile an action in circuit court to seek the unpaid rent. Birmingham Realty took the court's advice and filed the suggested motions. MPQ filed a motion to alter, amend or vacate the court's decision in its counterclaim. The circuit court did not rule on either motion. The parties appealed to the Supreme Court. Upon review, the Supreme Court found Birmingham Realty's appeal from the district court to the circuit court was not timely, and as such, the court did not have jurisdiction over the appeal. The Supreme Court dismissed the appeal and cross-appeal with regard to the unlawful-detainer action and remanded the remaining issues for further proceedings. View "MPQ, Inc. v. Birmingham Realty Co." on Justia Law

Appellee Younus Ismail, M.D. appealed a trial court's denial of his motion for summary judgment pertaining to claims made by Appellants Randy and Joy Paradise. Mr. Paradise was treated in the emergency room of Highlands Medical Center, and a chest x-ray was ordered as part of his treatment. While in the radiology department, he fell and was injured. Mr. and Mrs. Paradise filed suit alleging negligence and wantonness stemming from Mr. Paradise's injuries. Dr. Ismail was the emergency room physician "in charge and control of [Mr.] Paradise's treatment." The Doctor filed a motion to dismiss the charges, arguing the claim was barred by a two-year statute of limitations. Upon review of the trial court's record and the applicable legal authority, the Supreme Court found that the claim was indeed time-barred as to Dr. Ismail. The Court vacated the trial court's order denying the Doctor's motion and remanded the case for the trial court to enter summary judgment in the Doctor's favor. View "Paradise v. Highlands Medical Ctr." on Justia Law

RCH IV-WB, LLC (RCH) appealed a circuit court's order that set aside its mortgage foreclosure sale. At a bench trial, RCH offered as evidence a copy of a document allegedly assigning the mortgage at issue from Wachovia Bank to RCH. Defendant Wolf Bay Partners, LLC objected to the admission of the assignment documents, arguing that RCH failed to show that the individual who signed the assignment had authority to act, and that the form of the assignment failed to conform to Alabama law. The trial court sustained the objection and eventually set aside the foreclosure sale of the subject property. RCH unsuccessfully filed a motion for new trial and appealed to the Supreme Court. Upon review of the trial court record, the evidence submitted and the applicable legal authority, the Supreme Court concluded that the trial court erred in holding that the mortgage assignment was not admissible. The Court reversed the lower court's judgement and remanded the case for further proceedings. View "RCH IV-WB, LLC v. Wolf Bay Partners, L.L.C., et al." on Justia Law

Tellabs Operations, Inc. appealed an administrative agency's decision in its taxpayer's refund action from the circuit court. Tellabs unsuccessfully petitioned for a refund of allegedly overpaid sales taxes to the City of Bessemer. The case was originally filed in Montgomery Circuit Court. Bessemer filed a motion to dismiss, or in the alternative, to change venue to Jefferson Circuit Court. Without holding a hearing on the motion, the circuit court transferred the appeal to Jefferson Circuit Court. In its motion for reconsideration, Tellabs argued the Montgomery Court erred in transferring the appeal. The court responded that it had lost jurisdiction, and Tellabs' only remedy was to petition the Supreme Court. Upon review of the circuit court records, the Supreme Court concluded that the Montgomery Circuit Court erred in transferring the appeal to the Jefferson Court. The Supreme Court vacated the transfer order and remanded the case for further proceedings in Montgomery Circuit Court. View "Tellabs Operations, Inc. v. City of Bessemer " on Justia Law

Black Warrior Minerals, Inc. sued Empire Coal Sales, Inc. and John Fay, Jr. Black Warrior sought money allegedly owed pursuant to a coal-purchase agreement between Black Warrior and Empire and a personal guaranty executed by Mr. Fay. A trial court entered summary judgment in favor of Black Warrior, awarding it damages plus attorney fees and costs. The trial court held a bench trial on the breach-of-guaranty claim against Mr. Fay, entering judgment in favor of Mr. Fay. Black Warrior appealed the latter, arguing that the trial court erred in finding the language of the guaranty was ambiguous and applied only to amounts in excess of $1.2 million owed by Empire to Black Warrior. Upon review of the language of the guaranty and the applicable legal authority, the Supreme Court concluded the trial court erred in its interpretation of the guaranty's terms. The Court reversed the lower court's judgment and remanded the case for further proceedings. View "Black Warrior Minerals, Inc. v. Fay" on Justia Law