Justia Alabama Supreme Court Opinion Summaries

A firefighter employed by the City of Birmingham developed hypertension during his employment and applied to the City of Birmingham Retirement and Relief System for both extraordinary and ordinary disability benefits, arguing that his condition and the medications required to control it prevented him from safely performing his job. He detailed unsuccessful attempts to manage his hypertension with various medications and provided medical opinions supporting his claim that only beta-blockers, which are not recommended for firefighters, could control his blood pressure. The Board, after considering the opinion of its medical expert, denied both applications, concluding that he had not exhausted all other antihypertensive regimens.The firefighter sought review of the Board’s decisions by filing a petition for a writ of mandamus in the Jefferson Circuit Court, as permitted by statute. Initially, the circuit court dismissed the action for lack of service, but the Supreme Court of Alabama reversed that dismissal and remanded the case. After service was obtained, the respondents argued that the claim for extraordinary disability benefits failed as a matter of law because the hypertension was not caused by a specific workplace accident, and that the Board’s denial of ordinary disability benefits was not manifestly wrong. The circuit court denied the mandamus petition without a hearing or consideration of evidence beyond the pleadings.The Supreme Court of Alabama affirmed the circuit court’s denial of extraordinary disability benefits, holding that the statutory requirements were not met because the disability did not result from an accident at a definite time and place. However, the Supreme Court reversed the denial of ordinary disability benefits, finding that the circuit court erred by not allowing the petitioner to present evidence or reviewing the evidence considered by the Board. The case was remanded for further proceedings on the ordinary disability claim. View "Hoffman v. City of Birmingham Retirement and Relief System" on Justia Law

A lessor and two lessees entered into a lease with an option to purchase a residential property in Calhoun County, Alabama. The agreement required the lessees to make monthly rent payments, annual payments, and an initial deposit, with certain payments to be credited toward the purchase price if the option was exercised. Disputes arose near the end of the lease term regarding the timeliness of the lessees’ payments and whether the lessees had complied with all contractual requirements, including providing written notice of their intent to purchase.The Calhoun Circuit Court conducted a bench trial and found that a valid lease-to-purchase contract existed, that the lessees had complied with its terms, and that the lessor still owed a mortgage on the property. The court ordered that all funds held by the parties be paid to the lessor to reduce the mortgage principal, required the lessor to satisfy the mortgage and convey clear title to the lessees by a specified date, and assigned responsibility for property taxes to the lessees. The lessor’s postjudgment motion, which challenged the findings regarding compliance and payment timeliness, was denied.On appeal, the Supreme Court of Alabama reviewed the trial court’s factual findings under the ore tenus standard, deferring to the trial court’s credibility determinations unless clearly erroneous. The Supreme Court affirmed the trial court’s finding that the lessees had not breached the lease, concluding that the lessor’s actions had contributed to any payment delays. However, the Supreme Court reversed the trial court’s judgment to the extent it credited monthly rent payments toward the purchase price, holding that only the initial deposit and annual payments should be applied, as the contract unambiguously required. The case was remanded for further proceedings consistent with this holding. View "McCain v. Sneed" on Justia Law

A group of fourteen taxpayers, all out-of-state owners, operators, or lessees of multifamily housing developments in the City of Tuscaloosa, challenged a city ordinance that amended the business-license fee structure. The ordinance, effective April 2022, imposed a 3% business-license fee on rents received from student-oriented housing developments (SOHDs) with more than 200 bedrooms, while other rental properties remained subject to a 1% fee. The SOHD designation is determined by the city’s zoning officer based on a non-exhaustive list of characteristics and factors. The taxpayers alleged that the ordinance unfairly targeted out-of-state owners and was vague in its application.The taxpayers filed suit in the Tuscaloosa Circuit Court, seeking a declaration that the ordinance was invalid and a refund of taxes paid. They raised claims under the Equal Protection and Due Process Clauses, the dormant Commerce Clause, and argued that the ordinance was essentially a zoning ordinance adopted without following statutory notice requirements. The trial court granted the City’s motion to dismiss under Rule 12(b)(6), finding the complaint insufficient to state a claim.On appeal, the Supreme Court of Alabama reviewed whether the complaint alleged sufficient facts to survive dismissal. The court held that the taxpayers’ claims under the Equal Protection Clause, Due Process Clause (vagueness), and dormant Commerce Clause were sufficiently pleaded to withstand a motion to dismiss, as the allegations, if proven, could entitle the taxpayers to relief. However, the court affirmed the dismissal of the claim that the ordinance was a zoning ordinance subject to statutory notice requirements, finding the ordinance did not regulate property use in the manner of zoning laws. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "Campus Crest at Tuscaloosa LLC v. City of Tuscaloosa" on Justia Law

The case involves a dispute between the operator of a day-care center and various officials and employees of the Alabama Department of Human Resources (ADHR) and the Elmore County Department of Human Resources (EDHR). The operator applied to renew the day-care’s license, but a background check revealed that one employee, V.F., had a prior indicated report for child abuse. ADHR officials informed the operator that the license could not be renewed unless V.F. was terminated or cleared. After V.F. was terminated, further disputes arose regarding documentation and access to the facility. ADHR officials subsequently reported alleged deficiencies, leading to the temporary suspension and eventual revocation of the day-care’s license, as well as the operator’s arrest. The criminal charges were later dismissed, and after an administrative hearing, the day-care was relicensed.Previously, the administrative law judge (ALJ) conditionally affirmed ADHR’s decision to revoke the license but allowed for relicensing if the facility met standards. The Montgomery Circuit Court affirmed the ALJ’s decision, and the Alabama Court of Civil Appeals dismissed a further appeal as moot after the license was reissued. The operator and the day-care then filed a new lawsuit in circuit court against the DHR employees, alleging various torts and seeking declaratory relief. The DHR employees moved to dismiss, arguing collateral estoppel based on the prior administrative proceedings. The circuit court granted the motion, dismissing the claims.The Supreme Court of Alabama reviewed whether the circuit court properly dismissed the claims on collateral estoppel grounds. The Court held that, because the circuit court considered materials outside the complaint, the motion to dismiss was converted to a summary judgment motion. The Court found that the plaintiffs failed to adequately argue that collateral estoppel did not apply and affirmed the circuit court’s judgment. The Supreme Court of Alabama thus affirmed the dismissal of the claims. View "Williams v. Dodd" on Justia Law

Several individuals were convicted in separate proceedings in the Huntsville Municipal Court for violating city ordinances. Each person appealed his conviction to the Madison Circuit Court, seeking a trial de novo. Before those trials occurred, each defendant moved to dismiss the complaint, arguing that the municipal-court complaints failed to properly allege that the ordinances had been duly adopted and, in some cases, that the complaints referenced non-existent sections of the Alabama Code. All of these arguments were raised for the first time in the circuit court.The Madison Circuit Court granted the motions to dismiss in each case, sometimes stating that the complaints failed to confer jurisdiction. The City of Huntsville appealed these dismissals to the Alabama Court of Criminal Appeals, which consolidated the cases, reversed the circuit court’s judgments, and remanded for further proceedings. The defendants then sought review by the Supreme Court of Alabama, which consolidated the cases for decision.The Supreme Court of Alabama held that any defects in the municipal-court complaints did not deprive the circuit court of subject-matter jurisdiction, as that jurisdiction is conferred by statute. The Court further held that the defendants did not waive their challenges to the sufficiency of the complaints by failing to raise them in municipal court; such challenges could be raised during the pendency of the proceedings, including in the circuit court. However, the Court concluded that the municipal-court complaints met the requirements of the Alabama Rules of Criminal Procedure, specifically Rule 13.2(a), and did not need to include formal averments about the adoption of the ordinances. The Court affirmed the judgments of the Court of Criminal Appeals. View "Ex parte Sandifer" on Justia Law

On June 23, 2019, a multi-vehicle accident occurred on Interstate 59 in Birmingham, Alabama. John Daniels, Jr. lost control of his car after being struck by another vehicle and crashed into the concrete median, where his car was subsequently hit by other vehicles. Nicholas Raynard Smith, Jr., riding a motorcycle with a companion, approached the accident scene and collided with Daniels’s car, suffering severe injuries. There was conflicting evidence about whether the streetlights near the accident site were operational at the time, but it was undisputed that two specific streetlights were not working when first responders arrived. Smith alleged that the City of Birmingham was responsible for maintaining those streetlights and had been on notice of lighting problems in the area.Smith filed suit in the Jefferson Circuit Court, asserting claims of negligence and negligent hiring, training, supervision, and/or retention against the City. The court dismissed Smith’s wantonness and recklessness claims, leaving only the negligence-based claims. The City moved for summary judgment, arguing it was entitled to municipal and substantive immunity. The circuit court denied the motion, finding that factual questions remained regarding the City’s notice of the lighting issue and whether the inoperable streetlights proximately caused Smith’s injuries.The Supreme Court of Alabama reviewed the City’s petition for a writ of mandamus. The Court held that the City was entitled to substantive immunity on Smith’s negligence claim, concluding that a municipality’s voluntary maintenance of streetlights for public safety does not create a legal duty to individual motorists. The Court also noted Smith’s concession that his negligent hiring, training, supervision, and/or retention claim should be dismissed. Accordingly, the Supreme Court of Alabama granted the City’s petition and directed the circuit court to enter summary judgment in favor of the City. View "Ex parte City of Birmingham PETITION FOR WRIT OF MANDAMUS" on Justia Law

The case concerns an automobile accident that occurred in rural Tuscaloosa County, Alabama, on January 3, 2024. James Godwin, a resident of Dallas County and employee of Talton Communications, Inc., was driving a company vehicle when he was rear-ended by Desi Bernard Peoples, a resident of Fayette County. Godwin subsequently filed suit in the Dallas Circuit Court against Peoples, his employer Talton, and Penn National Security Insurance Company, which provided uninsured/underinsured motorist coverage. Godwin’s claims included negligence and wantonness, a claim for uninsured/underinsured motorist benefits, and a workers’ compensation claim against Talton. Godwin received all medical treatment for his injuries in Dallas County, where he and his wife reside and work.After the complaint was filed, Penn National moved to sever the workers’ compensation claim and to transfer the remaining claims to the Tuscaloosa Circuit Court, arguing that transfer was warranted for the convenience of the parties and witnesses and in the interest of justice under Alabama’s forum non conveniens statute, § 6-3-21.1. The Dallas Circuit Court denied the motion to sever but ordered the workers’ compensation claim to be tried separately. The court also denied the motion to transfer, finding insufficient evidence that Tuscaloosa County was a significantly more convenient forum or that Dallas County had only a weak connection to the case.The Supreme Court of Alabama reviewed Penn National’s petition for a writ of mandamus seeking to compel transfer. The Court denied the petition, holding that Penn National failed to meet its burden of showing that Tuscaloosa County was significantly more convenient or that Dallas County’s connection to the case was weak. The Court emphasized that the plaintiff’s choice of venue is entitled to deference when both venues are proper and that the evidence presented did not justify overriding that choice. View "Ex parte Penn National Security Insurance Company" on Justia Law

A Georgia corporation operates several hospitals and clinics in west Georgia and, through an affiliated entity, also operates a small hospital and clinics in east Alabama. An Alabama resident sought treatment at the Alabama hospital and was subsequently transferred by ambulance to the corporation’s Georgia facility for a heart-catheterization procedure. The procedure was performed by a Georgia-based physician employed by the corporation, who is not licensed in Alabama and has never practiced there. The patient alleges that the physician’s negligence during the procedure in Georgia caused him to suffer renal failure and require further medical intervention. The patient sued both the corporation and the physician in the Randolph Circuit Court in Alabama, asserting claims under both Alabama and Georgia medical liability statutes and alleging the corporation’s vicarious liability for the physician’s actions.The physician and the corporation moved to dismiss the case, arguing that the Alabama court lacked personal jurisdiction over them and that venue was improper. The circuit court dismissed the claims against the physician for lack of personal jurisdiction but denied the corporation’s motion to dismiss. The corporation then petitioned the Supreme Court of Alabama for a writ of mandamus to direct the circuit court to dismiss the claims against it.The Supreme Court of Alabama held that the corporation was not subject to general jurisdiction in Alabama, as it was neither incorporated nor had its principal place of business there. However, the Court found that specific personal jurisdiction existed because the patient’s treatment began at the Alabama facility operated by the corporation, and the subsequent care in Georgia was sufficiently related to the corporation’s activities in Alabama. The Court also concluded that the corporation had not demonstrated a clear legal right to dismissal based on improper venue, as it had not adequately addressed whether Alabama’s venue statute applied to claims brought under another state’s law. The petition for a writ of mandamus was denied. View "Ex parte Tanner Medical Center, Inc." on Justia Law

After the death of Arthur L. Bacon, Richard D. Gaynor, acting as the personal representative of Bacon’s estate, filed a lawsuit against Tom L. Larkin and Jerome B. Williams. The complaint alleged that a durable power of attorney in favor of Larkin was recorded shortly after Bacon’s death, though it was purportedly executed in 2019. It further claimed that, just hours before Bacon died, Larkin executed a deed transferring all of Bacon’s real property to Williams. The estate sought to void the conveyance and requested damages.Williams and Larkin each filed motions to dismiss. The Talladega Circuit Court granted Larkin’s motion to dismiss on March 3, 2025, but did not resolve the claims against Williams. On the same day, the court ordered the plaintiff to amend the complaint within 30 days to include necessary heirs or real parties in interest. Gaynor requested more time to respond, which both defendants opposed. On April 11, 2025, Gaynor filed a notice of appeal to the Supreme Court of Alabama, challenging the dismissal of Larkin. Subsequently, the circuit court entered an order stating that the dismissal of Larkin was a final order for purposes of appeal, referencing Alabama Rules of Civil Procedure.The Supreme Court of Alabama reviewed whether it had jurisdiction over the appeal. The Court held that, because the circuit court’s order did not dispose of all claims against all parties and lacked a proper Rule 54(b) certification at the time the notice of appeal was filed, there was no final judgment. The Court declined to remand for possible certification and dismissed the appeal for lack of a final, appealable order. View "Gaynor v. Larkin" on Justia Law

A group of plaintiffs filed suit against the Secretary of the Alabama Department of Workforce, alleging that the Department’s handling of their unemployment benefits applications during the COVID-19 pandemic was unlawful. The plaintiffs claimed that the Department’s policies and practices resulted in unreasonable delays and inadequate communication, violating both the Social Security Act and the Due Process Clause of the Fourteenth Amendment. They sought various forms of injunctive relief, including orders requiring prompt decisions on applications, timely payment of approved claims, and clearer communication with claimants.The Montgomery Circuit Court granted the Secretary’s motion to dismiss the case, without specifying the grounds for dismissal. The plaintiffs’ motion to alter or vacate the judgment was denied. On appeal, the Supreme Court of Alabama affirmed the dismissal, holding that the plaintiffs had not exhausted their administrative remedies and that the courts lacked the power to address the merits of their claims. The plaintiffs then sought review by the United States Supreme Court.The United States Supreme Court reversed the Alabama Supreme Court’s judgment, holding that the state’s administrative exhaustion requirement could not be used to bar federal due process claims under 42 U.S.C. § 1983 for alleged delays in processing unemployment benefits. On remand, the Supreme Court of Alabama considered supplemental briefing on whether the case had become moot, as the Secretary asserted that all plaintiffs had either been paid or received final denials. The plaintiffs disputed this and requested a remand for a factual determination. The Supreme Court of Alabama remanded the case to the Montgomery Circuit Court to determine whether the case is now moot, instructing the lower court to resolve the factual dispute regarding mootness. View "Johnson v. Reed" on Justia Law