Justia Alabama Supreme Court Opinion Summaries

The Tuscaloosa City Council passed an ordinance limiting the maximum occupancy of certain restaurants, affecting a sports bar owned by CMB Holdings Group. The ordinance required establishments with restaurant liquor licenses to maintain occupancy limits based on their configuration as restaurants, not as bars or entertainment venues. This change reduced the sports bar's maximum occupancy from 519 to 287, negatively impacting its revenue. CMB Holdings Group sued the City of Tuscaloosa, the mayor, city council members, and the fire marshal, alleging racial discrimination and other claims.The Tuscaloosa Circuit Court dismissed most of CMB's claims, including those for money damages against the City and personal-capacity claims against the mayor and councilors due to legislative immunity. The court also dismissed claims for procedural and substantive due process, equal protection, and others, leaving only claims for declaratory and injunctive relief under the Alabama Constitution's Contracts Clause. CMB requested the court to alter or amend its judgment or certify it as final for appeal purposes. The court denied the request to alter or amend but granted the Rule 54(b) certification, allowing CMB to appeal the dismissed claims.The Supreme Court of Alabama reviewed the case and determined that the Rule 54(b) certification was improper. The court found that the adjudicated and unadjudicated claims were closely intertwined, particularly regarding whether the ordinance affected vested rights or mere privileges and whether it served a legitimate public interest. The court concluded that separate adjudication could lead to inconsistent results and dismissed the appeal for lack of a final judgment. View "CMB Holdings Groupv. City of Tuscaloosa" on Justia Law

In this case, Universal Development Corporation ("Universal"), Hatti Group RE, LLC ("Hatti Group"), and Harsha Hatti separately appealed judgments entered by the Jefferson Circuit Court in favor of Robbie Dellinger following a jury trial. The trial involved consolidated cases with claims asserted by Hatti, the Hatti Group, and Dellinger.The Jefferson Circuit Court had previously dismissed Universal from Dellinger's initial action against Hatti and the Hatti Group. However, Universal was later brought back into the litigation when Hatti and the Hatti Group filed a separate action against Dellinger, Universal, and others. The cases were consolidated, and Dellinger asserted a breach-of-contract cross-claim against Universal. The jury found in favor of Dellinger on his claims against Universal and Hatti, awarding him compensatory and punitive damages.The Supreme Court of Alabama reviewed the appeals. It dismissed the appeals of Hatti Group and Hatti, noting that Hatti's appeal in Hatti v. Universal was invalid because no adverse judgment was entered against Hatti in that case. Hatti's appeal in Dellinger v. Hatti was dismissed as untimely because it was filed more than 42 days after the final judgment.Regarding Universal's appeal, the court reversed the judgment against Universal and rendered a judgment in its favor. The court held that Dellinger's breach-of-contract claim against Universal was void because it was based on work performed without a general contractor's license, violating Alabama's licensure statutes. The court concluded that Dellinger acted as a general contractor under the Personal Services Agreement with Hatti, and since Dellinger was unlicensed, the contract was void as a matter of public policy. Consequently, Universal had no legal obligation to support Dellinger in seeking payments under an unenforceable contract. View "Universal Development Corporation v. Dellinger" on Justia Law

In February 2019, the Colberts entered into a real-estate sales contract with A & W Contractors, LLC to purchase a remodeled 54-year-old house. A home inspection revealed issues with the plumbing, septic system, and electrical wiring. The parties amended the contract to address these issues, and A&W claimed to have made the necessary repairs. Despite lingering concerns, the Colberts proceeded with the purchase after A&W's real-estate agent allegedly offered a three-month builder's warranty. After moving in, the Colberts experienced significant problems with the house's systems and spent approximately $90,000 on repairs.The Colberts sued A&W, and the case went to trial in the Jefferson Circuit Court. The jury found in favor of the Colberts on their breach-of-contract and fraud claims, awarding them compensatory and punitive damages. The trial court entered a judgment on the jury's verdict and denied A&W's post-trial motions to alter, amend, or vacate the judgment or for a new trial.The Supreme Court of Alabama reviewed the case. It held that the trial court erred in granting a judgment as a matter of law (JML) in favor of the Colberts on their breach-of-contract claim, as there was conflicting evidence that should have been resolved by the jury. However, the Supreme Court affirmed the jury's verdict on the fraudulent misrepresentation and fraudulent suppression claims, noting that A&W had failed to preserve certain evidentiary and sufficiency-of-the-evidence arguments for appellate review. The case was affirmed in part, reversed in part, and remanded for further proceedings consistent with the opinion. View "A & W Contractors, LLC v. Colbert" on Justia Law

The case involves a dispute between Corporate Pharmacy Services, Inc. (CPS) and the defendants, Mobile Investments, LLC, and The Broadway Group, LLC (TBG). CPS sought to depose Robert Broadway, the corporate representative for Mobile Investments and TBG, but Broadway repeatedly canceled scheduled depositions, citing scheduling conflicts. CPS filed multiple motions to compel Broadway's deposition and to impose sanctions. The trial court granted CPS's motions to compel but initially denied the requests for sanctions. After Broadway continued to fail to appear for depositions, the trial court warned that a default judgment would be entered if he did not comply.The Etowah Circuit Court eventually entered a default judgment against Mobile Investments and TBG as a sanction under Rule 37(b)(2)(C) of the Alabama Rules of Civil Procedure, due to their repeated non-compliance with discovery orders. Mobile Investments and TBG moved for relief from the default judgment, arguing that their former attorney failed to inform them about the court's orders and the consequences of non-compliance. Their motion was denied, leading to the current appeal.The Supreme Court of Alabama reviewed the case and affirmed the trial court's decision. The court held that the default judgment was appropriate given the defendants' willful and repeated failure to comply with discovery orders. The court emphasized that knowledge of the attorney is imputed to the client, and the defendants could not hide behind their attorney's alleged omissions. The court found that the trial court had acted within its discretion in entering the default judgment as a sanction for the defendants' conduct. View "Mobile Investments, LLC v. Corporate Pharmacy Services, Inc." on Justia Law

Lavonne S. Mottern died after receiving a contaminated intravenous injection at Princeton Medical Center, operated by Baptist Health System, Inc. (BHS). Donald J. Mottern, as administrator of Lavonne's estate, filed claims against BHS, Meds I.V., LLC (the manufacturer of the injection), and three individuals associated with Meds I.V. The claims against Meds I.V. and the individuals were settled, leaving only the claims against BHS, which included negligence, wantonness, a claim under the Alabama Extended Manufacturer's Liability Doctrine (AEMLD), and a breach of implied warranty under the Uniform Commercial Code (UCC).The Jefferson Circuit Court dismissed all of Mottern's claims against BHS, including the negligence and wantonness claims, which BHS conceded should not have been dismissed. BHS argued that the AEMLD and UCC claims were subject to the Alabama Medical Liability Act (AMLA) and required proof of a breach of the standard of care. The trial court agreed and dismissed these claims, leading to Mottern's appeal.The Supreme Court of Alabama reviewed the case and agreed with BHS that all of Mottern's claims, including those under the AEMLD and UCC, are subject to the AMLA's standard-of-care provisions. The court held that the AMLA applies to all actions for medical injury, regardless of the theory of liability, and requires proof of a breach of the standard of care. The court reversed the trial court's dismissal of the negligence and wantonness claims and remanded the case for further proceedings consistent with its opinion. The main holding is that the AMLA's standard-of-care provisions apply to all claims alleging medical injury, including those under the AEMLD and UCC. View "Mottern v. Baptist Health System, Inc." on Justia Law

A Florida resident, Sheri Sawyer, acting as the personal representative of her deceased son Thomas's estate, filed a product-liability lawsuit against Cooper Tire & Rubber Company in the Mobile Circuit Court. The case arose from a fatal single-vehicle accident in Mobile County, Alabama, where a tire manufactured by Cooper Tire allegedly experienced tread separation, causing the vehicle to crash. The tire was purchased in Alabama by Barbara Coggin, the mother of the driver, Joseph Coggin, both Alabama residents.Cooper Tire moved to dismiss the case, arguing that Alabama courts lacked specific personal jurisdiction over it due to insufficient suit-related contacts with Alabama. Sawyer countered that Cooper Tire's extensive business activities in Alabama, including the sale, distribution, and advertising of the tire model in question, established sufficient contacts. While the motion was pending, the U.S. Supreme Court decided Ford Motor Co. v. Montana Eighth Judicial District Court, which held that specific personal jurisdiction could exist even without a direct causal link between the defendant's forum activities and the plaintiff's claims.The Mobile Circuit Court granted Cooper Tire's motion to dismiss, concluding that Sawyer failed to show that Cooper Tire sold, distributed, or marketed the specific tire model in Alabama within three years before the accident. The court also noted that neither Sawyer nor her son were Alabama residents, reducing Alabama's interest in providing a forum for the case. Sawyer appealed the decision.The Supreme Court of Alabama reversed the lower court's decision, applying the analytical framework from Ford. The court held that Cooper Tire's sale, distribution, and advertising of the tire model in Alabama "related to" Sawyer's claims, establishing specific personal jurisdiction. The court also found that the trial court's focus on the timing of Cooper Tire's contacts and Sawyer's residency was not dispositive. The case was remanded for further proceedings consistent with this opinion. View "Sawyer v. Cooper Tire & Rubber Company" on Justia Law

In 2014, several homeowners' associations sued Baldwin County Sewer Service, LLC (BCSS), alleging that a rate increase violated a 1991 agreement between a real-estate developer and BCSS. The plaintiffs sought a declaratory judgment and specific performance of the agreement. The case has been brought before the Supreme Court of Alabama multiple times, with BCSS repeatedly questioning whether the plaintiffs are successors in interest to the original contract party.The Baldwin Circuit Court initially granted summary judgment in favor of BCSS, stating that the plaintiffs lacked standing. However, the Supreme Court of Alabama reversed this decision in 2016, clarifying that the issue was not one of standing but whether the plaintiffs were real parties in interest. On remand, BCSS continued to challenge the plaintiffs' status, leading to multiple nonfinal rulings and additional appellate proceedings. The circuit court denied BCSS's summary judgment motions on this issue multiple times, including in August 2023.The Supreme Court of Alabama reviewed BCSS's petition for a writ of mandamus, which sought to compel the circuit court to grant summary judgment in its favor. The Court clarified that the real-party-in-interest question does not implicate the trial court's subject-matter jurisdiction and is not appropriate for mandamus review. The Court emphasized that such issues should be resolved through a final judgment by the trial court. Consequently, the Supreme Court of Alabama denied BCSS's petition for a writ of mandamus. View "Ex parte Baldwin County Sewer Service, LLC" on Justia Law

American Pride Properties, LLC ("APP") filed a lawsuit in the Jefferson Circuit Court against James R. Davis and William M. Pickard, seeking ejectment and damages for the loss of use of real property owned by APP. Pickard had initially shown interest in purchasing the property and was allowed to take possession for renovations before closing. However, the sale did not close as planned, and Pickard attempted to assign his rights to Davis, which led to confusion. Despite multiple extensions and addendums to the purchase agreement, the sale never closed, and APP considered the agreement canceled.The Jefferson Circuit Court held a bench trial and ruled in favor of APP on its ejectment claim, awarding possession of the property to APP and dismissing the counterclaims filed by Davis and Pickard. However, the court retained jurisdiction over APP's demand for damages related to the use and detention of the property. The court certified its judgment as final under Rule 54(b) of the Alabama Rules of Civil Procedure, leading Davis and Pickard to appeal.The Supreme Court of Alabama reviewed the case and determined that the Rule 54(b) certification was improper because the trial court had not resolved the issue of damages, which was part of the same claim for ejectment. The court emphasized that a claim is not fully adjudicated for Rule 54(b) purposes until all elements, including damages, are resolved. Consequently, the judgment was not final, and the Supreme Court of Alabama dismissed the appeals as premature due to lack of jurisdiction. View "Davis v. American Pride Properties, LLC" on Justia Law

Catalina Estillado died from injuries sustained in a workplace accident at ABC Polymer Industries, LLC. Her spouse, Crescencio Pablo, filed a wrongful-death claim against her coworkers, Dean Leader and William Durall, alleging their willful conduct caused her death by removing a safety guard from the machine involved. The Jefferson Circuit Court found in favor of Pablo, awarding $3 million in damages. Leader and Durall appealed.The circuit court determined that the machine was originally manufactured with a safety gate interlocked with a limit switch, which was later removed. The court concluded that Durall had effectively "removed" the safety device by not reinstalling it and by training employees to bypass it. The court also found that Durall knew injury was likely from this removal and that the removal was not part of a modification that rendered the safety device unnecessary.The Supreme Court of Alabama reviewed the case. It found that while the machine was originally manufactured with the safety device, there was no evidence that Durall knew the safety gate should be interlocked with a limit switch when he inspected and installed the machine. The court also noted that instructing employees to bypass a safety device does not equate to its removal under § 25-5-11(c)(2), referencing the precedent set in Williams v. Price. Additionally, Durall had left ABC Polymer before Estillado was hired and did not train her.The court concluded that Pablo failed to prove Durall willfully and intentionally removed the safety device. Consequently, the judgment against Durall was reversed, and the case was remanded for further proceedings. The appeal by Leader was dismissed due to his bankruptcy discharge. View "Leader v. Pablo" on Justia Law

Nicholas Hoffman, a former firefighter for the City of Birmingham, was released from duty in 2022 due to a medical condition. He applied for both extraordinary and ordinary disability benefits from the City of Birmingham Retirement and Relief System, but the Board of Managers denied his claims. Hoffman received notice of the denial on December 28, 2022. On March 10, 2023, he filed a petition for a writ of mandamus in the Jefferson Circuit Court to review the Board's decision.The Jefferson Circuit Court dismissed Hoffman's petition, citing improper service of process. Hoffman initially attempted service by certified mail, but the return receipts were signed by an employee of the City's finance department, not an authorized agent of the respondents. Hoffman then attempted service through the sheriff's office, but the summons was accepted by a city clerk, not the mayor or an authorized agent. The trial court granted the respondents' motion to quash service and ordered Hoffman to perfect service within 30 days. When Hoffman failed to do so to the court's satisfaction, the court dismissed the case with prejudice.The Supreme Court of Alabama reviewed the case and found that Hoffman had made diligent efforts to serve the respondents and had not exhibited a clear record of delay, willful default, or contumacious conduct. The court held that the trial court exceeded its discretion in dismissing the case with prejudice. The Supreme Court of Alabama reversed the trial court's judgment and remanded the case for further proceedings. View "Hoffman v. City of Birmingham Retirement and Relief System" on Justia Law