Justia Alabama Supreme Court Opinion Summaries

Several residents of the City of Muscle Shoals filed a lawsuit against the City, seeking damages for negligence and trespass due to flooding caused by the City's management of a stormwater-drainage pond in their neighborhood. The plaintiffs claimed that heavy rainfall in February 2019 overwhelmed the pond, leading to the flooding of their homes. They argued that the City failed to plan adequately for such events and did not maintain the pond properly.The plaintiffs initially filed their complaint in the Colbert Circuit Court in March 2020, seeking damages for negligence, wantonness, and trespass. They later amended their complaint to drop the wantonness claim and added a request for injunctive relief, which the trial court denied. The City moved for summary judgment, arguing that the claims were barred by § 11-47-190, Ala. Code 1975, and that there was no substantial evidence to support the trespass claim. The trial court denied the City's motion, leading the City to file a petition for a writ of mandamus with the Supreme Court of Alabama.The Supreme Court of Alabama reviewed the case and determined that the City was immune from the plaintiffs' claims under § 11-47-190, Ala. Code 1975. The Court found that the City's decision to plan for 25-year rainfall events was within common municipal practice and did not constitute neglect, carelessness, or unskillfulness. Additionally, the Court concluded that the City's design and maintenance of the pond were not defective within the meaning of the statute. As a result, the Court granted the City's petition and issued a writ directing the trial court to enter a summary judgment in favor of the City, effectively barring the plaintiffs' claims for damages. View "In re: Burrell v. City of Muscle Shoals" on Justia Law

Trista Carter entered into a contract with Johnny Mack Morrow and Martha Morrow to purchase a house and 245 acres for $1,600,000. The contract included provisions for earnest money and an arbitration clause. The sale did not close, and the Morrows sued Carter for breach of contract and sought damages, including the earnest money. They also named Crye-Leike, Inc., the company holding the earnest money, as a defendant.The Franklin Circuit Court reviewed the case and denied Carter's motion to compel arbitration. The court found that the arbitration clause did not apply to disputes arising under paragraphs 11 and 12 of the contract, which included the earnest money dispute. Carter filed a motion to alter, amend, or vacate the judgment, arguing that the breach-of-contract claim was not solely an interpleader action regarding the earnest money. The trial court denied Carter's postjudgment motions by operation of law.The Supreme Court of Alabama reviewed the case and held that the arbitration agreement in the contract specifically excluded disputes related to the earnest money, as outlined in paragraph 12. Therefore, the trial court properly denied the motion to compel arbitration for the interpleader claim. However, the court found that the breach-of-contract claim, which sought damages beyond the earnest money, was subject to arbitration under the contract's arbitration clause. The Supreme Court of Alabama affirmed the trial court's decision regarding the interpleader claim but reversed the decision regarding the breach-of-contract claim and remanded the case for further proceedings consistent with its opinion. View "Carter v. Morrow" on Justia Law

JohnsonKreis Construction Company, Inc. ("JohnsonKreis") served as the general contractor on a hotel-construction project in Birmingham, with Howard Painting, Inc. ("Howard") as a subcontractor. The subcontract agreement included an indemnity provision requiring Howard to indemnify JohnsonKreis for personal injury or death arising from Howard's negligence. Domingo Rosales-Herrera, an employee of a subcontractor working for Howard, died after falling from a window while attempting to load equipment into a trash box on a telehandler owned by JohnsonKreis. The personal representative of Rosales-Herrera's estate filed a wrongful-death lawsuit against both JohnsonKreis and Howard.The Jefferson Circuit Court granted summary judgment in favor of Howard and its insurers, Auto-Owners Insurance Company and Owners Insurance Company (collectively "Owners"), determining that the indemnity provision in the subcontract agreement was legally unenforceable. The court held that Alabama law does not allow for the apportionment of damages in a wrongful-death case, thus precluding proportional indemnification.The Supreme Court of Alabama reviewed the case and reversed the trial court's decision. The Supreme Court held that the subcontract agreement's proportional indemnity provision was legally enforceable under Alabama law. The court noted that parties may enter into agreements allowing for indemnification even for claims resulting solely from the negligence of the indemnitee. The court emphasized that such agreements are valid and enforceable if expressed in clear and unequivocal language.The Supreme Court remanded the case for further proceedings consistent with its opinion, instructing the trial court to consider the parties' evidentiary submissions and arguments regarding the interpretation and application of the disputed provisions of the subcontract agreement and the additional-insured endorsement. View "JohnsonKreis Construction Company, Inc. v. Howard Painting, Inc." on Justia Law

Island Girl Outfitters, LLC (IGO) operated a store called Hippie Gurlz at Eastern Shore Centre, an outdoor shopping mall owned by Allied Development of Alabama, LLC. IGO signed a five-year lease in late 2020 but closed the store after the first year due to slow sales. Allied Development filed a complaint in Baldwin Circuit Court seeking rent and other damages under the lease. The trial court entered a $94,350 judgment in favor of Allied Development against IGO and its owner, Anthony S. Carver, who had personally guaranteed the lease.The Baldwin Circuit Court granted partial summary judgment in favor of Allied Development, finding no genuine issues of material fact regarding IGO's liability for breaching the lease. The court then held a hearing to determine damages, ultimately awarding Allied Development $94,350. IGO and Carver appealed, arguing that Allied Development failed to market and maintain the mall adequately and that they should not be liable for future rent since the storefront was relet shortly after they vacated.The Supreme Court of Alabama reviewed the case de novo regarding the liability determination and under the ore tenus rule for the damages award. The court found that IGO and Carver failed to show that Allied Development had a contractual duty to market and maintain the mall in a specific manner. Therefore, the trial court's summary judgment on liability was affirmed. Regarding damages, the absence of a transcript from the damages hearing meant the court had to presume the trial court's findings were correct. Consequently, the $94,350 judgment was affirmed. View "Island Girl Outfitters, LLC v. Allied Development of Alabama, LLC" on Justia Law

Nancy Walker executed a will in 2011, leaving personal property to her stepchildren and sister, Beatrice Land, and specific real property to Beatrice. In 2020, Nancy executed a new will and a deed, leaving the same property to her stepgranddaughter, Magen Grimes, and Magen's husband, Joseph Culpepper. Nancy died three weeks later. Beatrice contested the validity of the 2020 will and deed, claiming Nancy lacked testamentary capacity and was under undue influence.The Russell Circuit Court held a jury trial, which found the 2020 will and deed invalid. The court entered a judgment on the jury's verdict and denied post-judgment motions from the proponents of the 2020 will and deed. Beatrice's request for costs incurred in challenging the will was also denied.The Supreme Court of Alabama reviewed the case. It affirmed the circuit court's judgment invalidating the 2020 will, finding sufficient evidence that Nancy lacked testamentary capacity. However, it reversed the judgment invalidating the 2020 deed, citing jurisdictional limitations. The court also reversed the denial of Beatrice's request for costs and remanded the case for further proceedings to determine the amount of costs and attorney fees, and who should pay them. View "Boykin v. Land" on Justia Law

In August 2022, Rebecca Henderson and her minor son were involved in an automobile collision in Alabama. Henderson, a Kentucky resident, had an insurance policy from Kentucky Farm Bureau Mutual Insurance Company (Kentucky Farm Bureau) that provided uninsured-motorist (UM) benefits. In July 2024, Henderson filed a complaint in the Baldwin Circuit Court, asserting a negligence/wantonness claim against the other driver, Trey Allan Knapp, and a claim for damages by contract against Kentucky Farm Bureau, alleging entitlement to UM benefits as Knapp had no liability insurance.Kentucky Farm Bureau moved to dismiss the claim, arguing that the Baldwin Circuit Court lacked personal jurisdiction over it, as it only does business in Kentucky and has no contacts with Alabama. The motion was supported by an affidavit from a Kentucky Farm Bureau employee. Henderson opposed the motion, arguing that the insurance policy provided nationwide coverage, thus establishing sufficient contacts with Alabama. The circuit court denied the motion to dismiss without explanation, leading Kentucky Farm Bureau to petition the Supreme Court of Alabama for a writ of mandamus.The Supreme Court of Alabama reviewed the case and concluded that Kentucky Farm Bureau did not have sufficient contacts with Alabama to establish personal jurisdiction. The court noted that the insurance policy was issued and delivered in Kentucky, and Kentucky Farm Bureau does not conduct business in Alabama. The court distinguished between providing liability coverage nationwide and being subject to contract claims in any state. Consequently, the court granted the petition and issued a writ of mandamus directing the Baldwin Circuit Court to dismiss Henderson's claim against Kentucky Farm Bureau for lack of personal jurisdiction. View "In re: Henderson v. Kentucky Farm Bureau Mutual Insurance Company" on Justia Law

Earnest Charles Jones was severely injured by a bull on August 27, 2018, and was transported by helicopter to the University of South Alabama Hospital. During the transport, flight nurse Bryan Heath Wester allegedly removed a nasal-gastro tube from Jones's throat, causing further injuries. Nearly two years later, Ovetta Jones, on behalf of Earnest, filed a lawsuit against Wester and Air Evac EMS, Inc., alleging negligence and wantonness related to the care provided during the transport.The Dallas Circuit Court initially reviewed the case, where the Joneses filed their complaint on August 24, 2020. The complaint focused on the removal of the nasal-gastro tube by Wester. Nearly four years later, the Joneses amended their complaint to include new allegations that Wester had stolen and replaced ketamine with saline solution the day before the transport, and that other flight nurses failed to detect this and properly treat Earnest's pain. Air Evac moved for summary judgment, arguing that the amended complaint was time-barred and did not relate back to the initial complaint. The trial court denied the motion.The Supreme Court of Alabama reviewed the case and determined that the amended complaint did not arise from the same conduct, transaction, or occurrence as the initial complaint. The amended complaint introduced entirely new facts and allegations, including actions by different individuals on a different day. Consequently, the amended complaint could not relate back to the initial complaint and was time-barred under the applicable statutes of limitations and repose. The Supreme Court of Alabama granted Air Evac's petition for a writ of mandamus, directing the trial court to vacate its order denying the summary judgment and to enter an order granting the motion. View "Ex parte Air Evac EMS, Inc." on Justia Law

Joyce Pates filed a medical malpractice lawsuit against Community Health Systems, Inc. (CHSI), Affinity Hospital, LLC, d/b/a Grandview Medical Center, Dr. John Kirchner, and Southlake Orthopaedics Sports Medicine and Spine Center, P.C. Pates alleged that after injuring her ankle and undergoing surgery performed by Dr. Kirchner at Grandview Medical Center, she experienced complications leading to an infection and ultimately the amputation of her right leg.The Jefferson Circuit Court denied the defendants' motions to dismiss, which argued that Pates's claims were barred by the two-year statute of limitations under the Alabama Medical Liability Act (AMLA). The court reasoned that Pates's injury began when she was informed of the need for amputation, thus starting the statute of limitations from that point.The Supreme Court of Alabama reviewed the case and determined that Pates's claims were indeed barred by the AMLA's statute of limitations. The court found that Pates's injuries, including signs of infection and the need for hardware removal, were evident by November 2020. Therefore, the statute of limitations began at that time, and Pates's complaint filed in February 2023 was outside the two-year limit. The court granted the petitions for writs of mandamus, directing the trial court to dismiss Pates's claims against the defendants. View "Ex parte Affinity Hospital, LLC" on Justia Law

Piedmont Comprehensive Pain Management Group, LLC ("Piedmont") provides pain-management care and had a business arrangement with DocRx Dispensing, Inc. ("DRD") for billing and collection services. DRD collected payments from insurance companies for medications dispensed by Piedmont and kept a portion as compensation. In 2022, Piedmont sued DRD and other related entities and individuals, alleging breach of contract, unjust enrichment, and various tort-based claims, accusing them of improperly depriving Piedmont of funds owed for dispensing medications.The Mobile Circuit Court initially granted the defendants' motion to compel arbitration based on an April 2017 agreement between Piedmont and DRD, which included an arbitration clause. The court stayed the action pending arbitration. During arbitration, the defendants produced a later August 2017 agreement, which also contained an arbitration clause and was signed by both parties. Piedmont then requested the trial court to lift the stay, arguing that the defendants could not insist on arbitration while denying the existence of the April 2017 agreement. The trial court lifted the stay, and the defendants appealed.The Supreme Court of Alabama reviewed the case de novo. The court held that claims based on the August 2017 agreement, which was signed by both parties, must be arbitrated. The court also noted that the trial court's initial order compelling arbitration of claims based on the April 2017 agreement was a final judgment, and Piedmont's failure to appeal within the required time frame meant the trial court had no jurisdiction to set aside that order. Consequently, the Supreme Court of Alabama reversed the trial court's order lifting the stay and remanded the case for further proceedings consistent with its opinion. View "DocRx, Inc. v. Piedmont Comprehensive Pain Management Group, LLC" on Justia Law

John Cassimus, Jason T. Carrick, and Ryan McAllister were members of several limited-liability companies operating retail-liquidation stores, which have since closed. Carrick and McAllister alleged that Cassimus misused corporate assets for personal gain, while Cassimus claimed that Carrick and McAllister enriched their own company, Xcess Limited, at the expense of the stores. Carrick and McAllister sued Cassimus and his associates in the Shelby Circuit Court, asserting various claims including breach of fiduciary duty and fraud.The Shelby Circuit Court denied the Cassimus defendants' motion to dismiss the derivative claims, appointed a special master to oversee discovery, and dismissed claims against East Hampton Advisors, LLC, based on the abatement statute. The Cassimus defendants and Carrick and McAllister sought mandamus review of these orders in the Supreme Court of Alabama.The Supreme Court of Alabama reviewed the petitions. In case no. SC-2024-0284, the court denied the Cassimus defendants' petition, holding that the question of whether Carrick and McAllister could fairly and adequately represent the companies was a fact-intensive inquiry not suitable for mandamus review at the pleading stage. In case no. SC-2024-0318, the court dismissed the Cassimus defendants' petition as untimely because it was filed outside the presumptively reasonable time without a statement of good cause. In case no. SC-2024-0349, the court denied Carrick and McAllister's petition, holding that they had another adequate remedy through a Rule 54(b) appeal, which they did not pursue.The court lifted the stay previously entered and directed the trial court to resume proceedings. View "Ex parte Cassimus" on Justia Law