Justia Alabama Supreme Court Opinion Summaries

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

Law enforcement officers attempted to stop a vehicle driven by Jeremy S. Mitchem after observing suspicious behavior and an expired tag. Mitchem fled, leading to a high-speed chase that ended in a collision. Upon searching the vehicle, officers found various controlled substances and $6,646 in cash on Mitchem’s person. Mitchem admitted to selling drugs and described his pricing, but claimed the cash was from his father to buy a vehicle. He denied knowledge of the drugs in the car and provided an alternative explanation for his actions.The Madison Circuit Court held a trial where the State sought forfeiture of the cash under the former version of § 20-2-93, Ala. Code 1975, arguing it was proceeds from or intended for drug transactions. The trial court, after hearing testimony and considering the evidence, found in favor of the State, concluding that the State had established a prima facie case for forfeiture. Mitchem’s postjudgment motion, which included an unsworn statement from his father about the source of the funds, was denied. Mitchem appealed.The Alabama Court of Civil Appeals reversed the trial court’s judgment, holding that the decision was against the great weight of the evidence because there was no concrete evidence tying the cash to a specific drug transaction. The State then sought review.The Supreme Court of Alabama granted certiorari, reversed the Court of Civil Appeals, and remanded the case. The Supreme Court held that the State is not required to trace seized currency to a specific drug transaction to meet its burden under the former § 20-2-93. The trial court’s finding that the cash was subject to forfeiture was not contrary to the great weight of the evidence, given Mitchem’s admissions and the circumstances of the seizure. View "In re Mitchem v. State" on Justia Law

After Minnie Pearl Harvey’s death, her son petitioned to probate her will and was granted letters testamentary by the Pike Probate Court. Harvey’s sister, Inez Lee, contested the will and requested a protective order. The probate court responded by revoking the son’s letters testamentary and appointing K. Nickie Bateman, an attorney, as administrator ad litem for the estate. Bateman performed various administrative duties and later submitted an invoice for her services. Lee objected to the invoice, arguing the fees were unreasonable. The parties reached a stipulation to dismiss the will contest, agreeing that Bateman’s fees would be paid from estate funds, and the probate court entered an order consistent with this agreement.The Pike Probate Court held a hearing on Lee’s objection to Bateman’s fees and ultimately found the requested amount reasonable, ordering the estate to pay Bateman’s full invoice. Lee appealed to the Pike Circuit Court, which reviewed the reasonableness of Bateman’s fees. The circuit court determined that Bateman’s hourly rate should be reduced and recalculated her compensation at a lower rate, awarding her less than the amount approved by the probate court. The circuit court left all other aspects of the probate court’s judgment undisturbed.The Supreme Court of Alabama reviewed the case and held that the circuit court, acting in its appellate capacity, erred by substituting its judgment for that of the probate court regarding the reasonableness of Bateman’s compensation. Because the record did not include a transcript or statement of the evidence from the probate court hearing, the circuit court was required to presume the probate court’s findings were correct. The Supreme Court of Alabama reversed the circuit court’s judgment and remanded the case for further proceedings consistent with its opinion. View "Bateman v. Lee" on Justia Law

Corey Lee Walton was convicted of reckless manslaughter after allegedly shooting and killing Christopher Champion during a brawl at a party. The evidence at trial indicated that Walton and his friend were pursued and surrounded by a group intending to harm them. Walton pulled a gun and, while being tackled, allegedly fired it, resulting in Champion’s death. Walton’s defense argued both that the prosecution had not proven he was the shooter and, alternatively, that he acted in self-defense. Walton was also charged with second-degree assault for allegedly shooting his friend, but was acquitted of that charge.The case was first tried in the Tuscaloosa Circuit Court, where the State introduced evidence of Walton’s prior criminal convictions, including attempted murder and other offenses, which had led to a court order prohibiting him from possessing firearms. The trial court admitted this evidence, reasoning it was relevant to whether Walton was acting unlawfully and thus not entitled to a “stand your ground” defense. Walton’s counsel objected, arguing that only common-law self-defense was at issue, not stand-your-ground, and that the details of the prior convictions were highly prejudicial. The trial court instructed the jury that Walton had a duty to retreat and that the prior crimes were relevant only to his illegal possession of the firearm.The Alabama Court of Criminal Appeals affirmed the conviction, finding the admission of the prior crimes evidence permissible. On certiorari review, the Supreme Court of Alabama held that the trial court abused its discretion by admitting details of Walton’s prior crimes, as they were irrelevant and unduly prejudicial given the defense’s concession regarding unlawful firearm possession and the absence of a stand-your-ground claim. The Supreme Court reversed the judgment of the Court of Criminal Appeals and remanded the case for further proceedings. View "Walton v. State" on Justia Law

Karl and Tonya Williams contracted with Whitson Builders, LLC to purchase a custom modular home manufactured by Franklin Structures, LLC. The sales contract specified that Franklin would provide all warranties for the home, and Whitson would assemble it on the Williamses’ property. After moving in, the Williamses experienced significant issues with the home’s construction and alleged that Franklin and Whitson failed to properly repair these defects despite multiple requests. The Williamses subsequently filed suit in Baldwin Circuit Court against Franklin, Whitson, and other parties, asserting claims including breach of contract, fraud, negligence, and breach of express and implied warranties.In Baldwin Circuit Court, Franklin moved to compel arbitration based on a provision in its homeowner’s manual, which required disputes to be submitted first to nonbinding mediation and, if unresolved, to binding arbitration. Franklin argued that the Williamses were bound by this provision because they had accepted warranty services and asserted express-warranty claims. The Williamses opposed, contending they never received or signed the manual containing the arbitration clause and did not assent to its terms. The trial court denied Franklin’s motion to compel arbitration in part.The Supreme Court of Alabama reviewed the trial court’s denial de novo. The Court held that the Williamses were contractually bound by the arbitration provision in Franklin’s warranty because they accepted warranty services and asserted express-warranty claims, following precedent from Southern Energy Homes, Inc. v. Ard. The Court found that the trial court erred by not compelling mediation and, if necessary, arbitration as required by the warranty’s terms. The Supreme Court of Alabama reversed the trial court’s order and remanded the case for entry of an order consistent with the arbitration provision. View "Franklin Structures, LLC v. Williams" on Justia Law