Justia Alabama Supreme Court Opinion Summaries

Two sisters, aged twelve and nine, were sexually abused by their tutor during sessions at public libraries owned by two Alabama municipalities in 2017. The abuse was witnessed by library employees who allegedly failed to intervene or report the misconduct. The sisters disclosed the abuse to their mother later that year, prompting a police report. In 2023, the tutor was convicted of sexual abuse. In 2024, the sisters and their mother sued the municipalities, asserting negligence in failing to respond to the abuse.The initial complaint named nonprofit corporations associated with the libraries as defendants but was amended to substitute the municipalities themselves. Prior to filing the amended complaint, the plaintiffs served notices of claim to each municipality, but these were submitted more than six years after the alleged tortious conduct. Both the City of Irondale and the City of Birmingham moved to dismiss, arguing noncompliance with Alabama Code § 11-47-23, which requires notice of claim against a municipality within six months of claim accrual. The Jefferson Circuit Court granted their motions, dismissing the claims.On appeal, the Supreme Court of Alabama considered whether minors are exempt from the six-month notice requirement under § 11-47-23. The plaintiffs argued that minority status should toll the notice period, referencing statutory provisions that extend the time for filing suit by minors. The Supreme Court of Alabama held that § 11-47-23 contains no exception for minors and that the statutory tolling provision applies only to statutes of limitations, not notice-of-claim statutes. The court affirmed the Jefferson Circuit Court's dismissal of the claims against both municipalities, holding that minors are subject to the same notice requirements as adults under Alabama law. View "A.G.R. v. The City of Irondale" on Justia Law

The case involves the family of a deceased inmate who alleged that certain medical professionals and a health services foundation, after performing an autopsy at the request of correctional authorities, removed and retained the decedent’s organs without family consent. The family contended they were not informed or asked for permission regarding the autopsy or retention of organs, and only learned the organs were missing when preparing the funeral. They claimed to have relied on statements from hospital staff that such practices were standard, and only discovered in December 2023, through media reports, that retention of organs without next-of-kin consent was allegedly unlawful.The Montgomery Circuit Court reviewed and denied the defendants’ consolidated motion to dismiss, finding that statutory limitations could be tolled due to alleged fraudulent concealment. The court determined that the amended complaint sufficiently alleged facts that, if proven, could justify equitable tolling under Alabama law, and that the family’s claims were not time-barred because they filed suit within two years of learning the alleged conduct was illegal.On review, the Supreme Court of Alabama considered a petition for writ of mandamus by the University of Alabama Health Services Foundation and Dr. Stephanie Reilly. The Court held that mandamus relief was appropriate because, from the face of the complaint, the claims were barred by applicable statutes of limitations. The Court reasoned the causes of action accrued by November 6, 2021, when the family learned the organs were missing, and rejected arguments for tolling or for treating the alleged conduct as a continuous tort. The Court distinguished between statutes of limitations governing different claims, and found that all claims against the petitioners except the AUAGA claim were time-barred. It therefore granted the petition and directed dismissal of all claims against the petitioners except for the AUAGA claim. View "Ex parte University of Alabama Health Services Foundation" on Justia Law

A veteran and his spouse obtained a VA-guaranteed loan to purchase a home. After the veteran’s employment was disrupted due to the U.S. withdrawal from Afghanistan, the couple experienced financial hardship and defaulted on their mortgage. The lender, a bank, initiated foreclosure proceedings. The couple attempted to reinstate their mortgage by tendering the full amount to bring the loan current, as provided by the mortgage contract, but allege that the bank and its foreclosure law firm failed to accept their payment or provide a means for payment. The property was sold to third-party purchasers at a foreclosure sale for more than the outstanding loan balance. The couple claims they did not receive adequate notice or an opportunity to exercise their statutory right of redemption.The third-party purchasers filed an ejectment action in Madison Circuit Court. The couple defended against the action and brought counterclaims against both the purchasers and the bank, alleging breach of good faith and fair dealing, breach of contract, wrongful foreclosure, unjust enrichment, and seeking declaratory relief. The trial court dismissed all claims against the bank and the third-party purchasers and granted summary judgment on the ejectment. The couple amended their pleadings, but the trial court again dismissed all claims. They appealed to the Supreme Court of Alabama. During the appeal, they settled with the third-party purchasers, leaving only their claims against the bank.The Supreme Court of Alabama held that Alabama law does not recognize an independent cause of action for breach of the duty of good faith and fair dealing and affirmed dismissal of that claim. However, the Court found that the couple adequately pleaded claims for breach of contract (due to the bank’s alleged refusal to allow reinstatement), wrongful foreclosure, and unjust enrichment. The Court reversed dismissal of those claims and remanded the case for further proceedings. View "Laborde v. Citizens Bank, N.A." on Justia Law

A group of property owners and their subdivision’s architectural committee initiated a lawsuit against two individuals and their investment company, alleging that the defendants began residential construction on two lots within a Guntersville subdivision without necessary building permits, failed to follow approved construction plans, and violated local building codes. The subdivision was governed by recorded restrictive covenants requiring written approval from the architectural committee for all construction. The defendants, who are experienced in homebuilding and acknowledged their awareness of the covenants, submitted plans and received approval but later built structures that did not conform to the approved plans and did not seek further approval for significant changes.The Marshall Circuit Court granted summary judgment in favor of the plaintiffs on the defendants’ counterclaims and conducted a bench trial. The trial court found that the defendants knowingly violated the restrictive covenants by constructing unapproved structures and rejected the argument that initial approval allowed them to build anything they chose. The court ordered the defendants to either bring the construction into compliance with previously approved plans, seek new approval within 30 days, or submit a removal plan for the unapproved structures if approval was not obtained. The defendants’ motions to alter the judgment or extend time for approval were denied.On appeal, the Supreme Court of Alabama examined whether the trial court erred by not applying the relative-hardship test, which can prevent enforcement of covenants if the hardship to the violator greatly outweighs the benefit to those enforcing them. The Supreme Court held that, although the defendants did not waive the hardship defense, the trial court properly declined to apply it because the defendants’ willful and intentional misconduct—knowingly constructing non-conforming structures—barred them from equitable relief under the clean-hands doctrine. The Supreme Court of Alabama affirmed the trial court’s judgment. View "Dendy v. Ryan" on Justia Law

A dispute arose from a business relationship between an individual and a contracting company, resulting in complex litigation in Texas. In 2012, the company sued the individual in Texas for fraud, and after a jury trial, a judgment was entered against the individual, awarding substantial compensatory and punitive damages, attorney fees, and interest. While the individual appealed the Texas judgment, the company initiated proceedings in Alabama to domesticate the Texas judgment under the Uniform Enforcement of Foreign Judgments Act. The Baldwin Circuit Clerk issued a certificate of judgment, and the individual unsuccessfully sought to stay enforcement of the domesticated judgment pending the Texas appeal.The Texas intermediate appellate court affirmed the judgment, but in April 2024, the Supreme Court of Texas reversed the judgment and remanded for determination of a settlement credit and entry of a new judgment. In November 2024, the individual filed a motion under Rule 60(b)(5), Alabama Rules of Civil Procedure, in Baldwin Circuit Court, seeking relief from the domesticated judgment on the basis that the underlying Texas judgment had been reversed. The circuit court denied the motion without a hearing, finding that Rule 60(b)(5) was not the appropriate procedural mechanism because it requires two separate judgments, and domestication does not create a second judgment independent of the foreign judgment.On appeal, the Supreme Court of Alabama reviewed whether the circuit court exceeded its discretion in denying relief. The court held that the circuit court did not abuse its discretion, finding that Rule 60(b)(5) does not apply to a domesticated foreign judgment based solely on the reversal of the underlying foreign judgment, and the individual failed to show entitlement to relief under any other subsection of Rule 60(b). The Supreme Court of Alabama affirmed the order of the circuit court. View "Shumate v. Berry Contracting L.P." on Justia Law

A mother, acting on behalf of her minor child, brought medical malpractice claims against a hospital, a medical practice, and a physician after her child suffered injuries during birth. She alleged that the defendants failed to meet the applicable standard of care before, during, and after delivery, including failing to discuss delivery options, improperly conducting the delivery resulting in a shoulder injury, and failing to perform certain ultrasounds. The original and first amended complaints detailed specific alleged breaches of care. After fact discovery concluded, the mother disclosed expert witnesses whose opinions went beyond the scope of the existing pleadings, addressing acts or omissions not previously alleged.The defendants moved to strike the portions of the expert disclosures related to these new allegations. In response, the mother filed second amended complaints, adding new claims based on the acts and omissions identified by her experts, including allegations concerning the administration of Pitocin, repair of a perineal tear, and additional alleged nursing errors. The defendants then moved to dismiss these new allegations, arguing they were untimely under Alabama’s Medical Liability Act (AMLA), which requires timely amendment of complaints upon learning of new or different acts or omissions. The Talladega Circuit Court denied the motions to dismiss and motions to strike, reasoning that the amendments were timely because they were filed more than 90 days before trial and soon after the close of discovery.Reviewing the matter on petitions for writs of mandamus, the Supreme Court of Alabama held that the new allegations in the second amended complaints were not timely under AMLA § 6-5-551. The Court concluded that the plaintiff had knowledge of the facts underlying the new claims well before amending and failed to act promptly as required by statute. The Court directed the trial court to grant the motions to dismiss the new allegations, but the plaintiff’s remaining, timely claims could proceed. View "Ex parte Coosa Valley Medical Center" on Justia Law

A municipal water and gas board entered into four contracts with a contractor to replace and expand gas lines in and around a city. The total project cost exceeded $4 million, and the contractor began work after being the sole bidder for each project phase. After paying the contractor over $2.8 million, the board ceased payments, leaving over $800,000 due for completed work. The board asserted it could not continue payments because the advertisement for sealed bids had not strictly complied with the version of the applicable Alabama statute in effect at the time the bids were solicited. The contractor then sued the board for breach of contract and other claims.The Franklin Circuit Court granted summary judgment for the board, finding, in effect, that strict compliance with the statutory advertising requirements was necessary and that the contracts were void due to noncompliance. The trial court denied the contractor’s postjudgment motion, and the contractor appealed.The Supreme Court of Alabama reviewed the case de novo. It held that substantial compliance, rather than strict compliance, with the advertising requirements for public works contracts under the relevant statute can satisfy the law’s objectives. The court distinguished this situation from prior precedent where there was a complete absence of competitive bidding and evidence of favoritism or corruption. Here, there was no such evidence, and the board had taken affirmative steps to advertise, including publication and online postings. The court concluded that the contractor presented substantial evidence of substantial compliance, creating a genuine issue of material fact. The Supreme Court of Alabama reversed the summary judgment and remanded the case for further proceedings. View "Pinpoint Locating, Inc. v. The Water Works and Gas Board of the City of Red Bay" on Justia Law

Michael Dixon and Kalie Dixon entered into a contract with Best Choice Roofing Alabama, LLC for the replacement of the roof on their home in Washington County, Alabama. After the work was completed, the Dixons noticed leaks and water damage, and despite contacting the company and providing an opportunity to fix the issues, their concerns were not resolved. They alleged that their house became nearly uninhabitable and sought damages for breach of contract and wantonness.Best Choice Roofing Alabama moved to dismiss the claims for improper venue, pointing to a forum-selection clause in the contract requiring any lawsuits to be brought in Sumner County, Tennessee, under Tennessee law. The Dixons argued that enforcing this clause would be seriously inconvenient and deprive them of their day in court, citing financial hardship, the distance to Tennessee, and the location of evidence and witnesses in Alabama. The Washington Circuit Court denied the motion to dismiss, finding the forum-selection clause clearly unreasonable and the chosen forum seriously inconvenient due to the circumstances faced by the Dixons, including their financial situation and the impact of the alleged damage.The Supreme Court of Alabama reviewed the trial court’s denial of the motion to dismiss through a petition for writ of mandamus. Applying Alabama law, the Supreme Court held that outbound forum-selection clauses are enforceable unless enforcement would be unfair or unreasonable. The Court found that the Dixons failed to meet their burden to show that enforcement would deprive them of their day in court or that extraordinary facts justified disregarding the clause. The Court concluded that the trial court exceeded its discretion and granted the petition, directing the trial court to dismiss the claims against Best Choice Roofing Alabama. View "Ex parte Best Choice Roofing Alabama, LLC" on Justia Law

The dispute centers on the ad valorem tax assessments for a low-income-housing property purchased in 2019 by Southampton 100, LLC. Dissatisfied with the Jefferson County Tax Assessor's valuations for several tax years, Southampton sought adjustments from the Jefferson County Board of Equalization and Adjustments. While the Board reduced some assessments, Southampton remained dissatisfied and filed separate appeals for each tax year. These appeals were consolidated in the Jefferson Circuit Court, where the Alabama Department of Revenue (ADOR) became the appellee.As the consolidated appeal progressed, the parties encountered repeated discovery disputes. ADOR filed multiple motions for sanctions, culminating in a request to depose Southampton’s second corporate representative, who resided in California, in person in Alabama. Southampton argued that requiring travel was unduly burdensome, offering instead to make this representative available via Zoom or for an in-person deposition immediately before trial. However, Southampton never sought a formal protective order. ADOR persisted and, after additional scheduling complications and denied motions, requested dismissal of the appeal as a sanction for alleged noncompliance. The Jefferson Circuit Court granted this request and dismissed Southampton’s appeal with prejudice, without a hearing or explanation.The Supreme Court of Alabama reviewed the case, applying the standard of whether the trial court exceeded its discretion in imposing sanctions. The Court held that dismissal with prejudice is a severe sanction that requires a showing of willful and deliberate disregard for discovery obligations. The record did not support a finding that Southampton acted willfully or intentionally to prevent discovery. Therefore, the Supreme Court of Alabama reversed the circuit court’s judgment and remanded the case for further proceedings. View "Southampton 100, LLC v. Alabama Department of Revenue" on Justia Law

A business dispute arose when an individual agreed to sell her furniture and design company to a limited liability company controlled by two individuals for $2.7 million, with payment to be made in installments. The seller also entered into a consulting agreement to assist in the transition but was terminated a few months later. The seller alleged that she did not receive compensation due under the consulting agreement and that the buyer failed to pay the final installment of the purchase price. She asserted claims for breach of contract, unjust enrichment, fraudulent inducement, and promissory fraud. The defendants counterclaimed and brought in several third parties, but most of those claims were eventually dismissed, leaving several claims—including for declaratory judgment, conversion, slander, breach of contract, and tortious interference—still pending.The Cullman Circuit Court tried only the seller’s promissory fraud and fraudulent inducement claims against the two individual defendants, entering judgment based on a jury verdict for the seller and awarding over $10 million in damages. The court stayed all claims against the corporate defendants after they filed for bankruptcy. Despite multiple claims and parties remaining, the circuit court certified its judgment against the individuals as final under Rule 54(b) of the Alabama Rules of Civil Procedure.Upon review, the Supreme Court of Alabama determined that the circuit court’s Rule 54(b) certification was improper. The Supreme Court found that closely intertwined and factually overlapping claims, counterclaims, and third-party claims remained unresolved, and that proceeding in piecemeal fashion risked inconsistent results and unnecessary duplication. The Supreme Court dismissed the appeal, holding that the circuit court’s order was not properly certified as final and thus was not appealable at this stage. View "Roberson v. Daniel" on Justia Law