Justia Alabama Supreme Court Opinion Summaries

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

Jessica De'Andrea, a patrol officer with the Montgomery Police Department, was involved in a motor vehicle collision while on duty. The driver of the other vehicle, Clint Walters, later sued De'Andrea individually for negligence, resulting in a $550,000 judgment against her after a jury trial. De'Andrea alleged that the City of Montgomery, which had procured liability insurance and acted as a self-insurer for its employees, failed to properly defend her, did not communicate settlement or appeal options, and refused to satisfy the judgment. She claimed these failures led to her bankruptcy and brought multiple claims against the City, including breach of contract, bad faith, fraudulent misrepresentation, and violations of the Alabama Legal Services Liability Act.The Montgomery Circuit Court denied the City's motions to dismiss, finding it was not apparent beyond doubt that De'Andrea could prove no set of circumstances entitling her to relief. The City then petitioned the Supreme Court of Alabama for a writ of mandamus, seeking dismissal of all claims on the basis of statutory immunity and other defenses.The Supreme Court of Alabama reviewed only the City's immunity defense as to the fraudulent misrepresentation claim, because the City had not preserved immunity arguments for the other claims in the lower court. The Court held that municipal immunity under § 11-47-190, Ala. Code 1975, does not automatically bar all fraudulent misrepresentation claims, as such claims can be based on innocent or mistaken misrepresentations, not just intentional torts. The Court denied the City's petition for a writ of mandamus, allowing De'Andrea's claims to proceed. The City may raise its other defenses on appeal if necessary. View "De'Andrea v. City of Montgomery" on Justia Law

A woman named Susan Bonner was involved in a car accident in Cherokee County, Alabama, where her vehicle ended up submerged in a creek. After being rescued by bystanders, one of whom was a volunteer firefighter from a different department, Bonner received CPR until Howard Guice, a volunteer firefighter and EMT with the Cedar Bluff Volunteer Fire Department (CBVFD), arrived. Guice, who was not dispatched to the scene and was outside his department’s service area, advised that resuscitative efforts should cease and reported a death over his radio. Paramedics arrived shortly after, found Bonner still had signs of life, and continued CPR, but she died two days later from anoxic encephalopathy.Carol Rogers, as administratrix of Bonner’s estate, filed a wrongful death lawsuit against Guice, the CBVFD, and others, alleging that Guice’s actions were negligent and that the CBVFD and its parent municipality, the Town of Cedar Bluff, were vicariously liable. The Cherokee Circuit Court found that the CBVFD was not a separate legal entity but a subordinate part of the Town. Relying on the Supreme Court of Alabama’s prior decision in Hollis v. City of Brighton, the court held that both Guice and the Town were immune from liability under Alabama’s Volunteer Service Act (VSA) and entered summary judgment in favor of the Town.On appeal, the Supreme Court of Alabama affirmed the trial court’s summary judgment. The Court held that the CBVFD is a subordinate entity of the Town, not a separate nonprofit, and that under the VSA, volunteer firefighters are immune from liability for negligence. Consequently, the Town cannot be held vicariously liable for the acts or omissions of its volunteer firefighters when they are immune under the VSA. The Court also clarified that municipalities cannot be held liable for wanton conduct by their volunteers. View "Rogers v. Cedar Bluff Volunteer Fire Department" on Justia Law

The owners of a lot in the Silver Cay II subdivision on Dauphin Island began constructing a house through their contracting company after obtaining a building permit from the Town of Dauphin Island. However, they did not secure a separate permit from the Dauphin Island Property Owners Association (DIPOA), as required by restrictive covenants applicable to their property. The DIPOA issued a stop-work order, alleging that the construction violated covenants both by lacking DIPOA approval and by extending the house beyond a 90-foot setback from the road. The owners continued some work to avoid material loss and later sought a variance from the DIPOA, obtaining consents from immediate neighbors, but the DIPOA board denied the variance.The DIPOA filed suit in the Mobile Circuit Court, seeking declaratory and injunctive relief to halt construction and require removal of the portions of the house violating the setback. The owners counterclaimed, seeking to compel the DIPOA to enforce the same covenants against a neighbor, but did not name the neighbor as a party. After a bench trial, the Mobile Circuit Court found the owners in violation, granted a permanent injunction requiring removal of the offending portions of the house, denied the counterclaim, and declined to award attorney fees to either party.On appeal, the Supreme Court of Alabama reviewed whether the trial court erred in granting injunctive relief. The Supreme Court held that, although the owners had breached unambiguous restrictive covenants, the harm to them from enforcing the injunction was considerably disproportionate to any benefit to the DIPOA. The Court concluded that the trial court’s failure to apply the relative-hardship test was manifestly unjust. The Supreme Court of Alabama reversed the trial court’s judgment and rendered judgment in favor of the owners, and dismissed the DIPOA’s cross-appeal regarding attorney fees as moot. View "Englund v. Dauphin Island Property Owners Association" on Justia Law

Daniel Flickinger, a litigator at Wainwright, Pope & McMeekin, P.C. (WPM), posted conservative commentary on his personal social media, including a controversial post about George Floyd. Lawrence Tracy King, a partner at King Simmons Ford & Spree, P.C., sent a screenshot of Flickinger’s post—paired with a professional photo from WPM’s website—to WPM partners, expressing concern about the post’s impact on the firm’s reputation. The WPM partners, after reviewing Flickinger’s social media activity and discussing with King, asked Flickinger to resign, which he did. Flickinger alleged that the screenshot misrepresented his post as being made in his professional capacity and falsely associated his views with WPM.Flickinger sued King and the King law firm for defamation, invasion of privacy, and tortious interference with a business relationship. The Jefferson Circuit Court dismissed all claims, but the Supreme Court of Alabama previously reinstated the tortious interference claim, remanding for further proceedings. On remand, the King defendants moved for summary judgment, submitting affidavits from WPM partners stating their decision to terminate Flickinger was based solely on their independent review of his public posts, not on King’s actions. Flickinger sought to compel production of King’s cell phone records and to continue the summary judgment hearing, but the circuit court denied both motions and granted summary judgment for the King defendants, finding no genuine issue of material fact on causation.The Supreme Court of Alabama affirmed summary judgment for the King law firm, holding King’s actions were outside the scope of his employment and did not benefit the firm. However, the Court reversed summary judgment for King, finding genuine issues of material fact regarding causation and justification. The case was remanded for further proceedings against King, while the denial of Flickinger’s discovery and continuance motions was affirmed. View "Flickinger v. King" on Justia Law

Bradley Lewis, acting on behalf of iWTNS, Inc. and Leveraged, LLC, entered into a contract with MotionMobs, LLC to develop a mobile-phone application intended to help users contact legal counsel during police stops. The contract specified a timeline and an hourly billing rate. Disputes arose regarding payment and the quality of the delivered product, leading MotionMobs to file a breach-of-contract suit against Lewis and the companies in the Jefferson Circuit Court. During litigation, Lewis and MotionMobs’ CEO exchanged text messages discussing a possible settlement, with Lewis proposing a payment schedule and MotionMobs responding with additional terms.The Jefferson Circuit Court reviewed MotionMobs’ motion to enforce the text-message exchange as a binding settlement agreement. The court found that the parties had entered into a valid agreement based on the text messages and ordered them to execute a written agreement reflecting those terms. The defendants sought relief from this order, which was denied, and MotionMobs moved to hold them in contempt for noncompliance. After procedural developments, including an initial dismissal of an appeal for lack of a final order, the circuit court entered a final judgment, prompting a timely appeal by the defendants.The Supreme Court of Alabama reviewed the case de novo, focusing on whether the text-message exchange constituted a binding settlement agreement. The Court held that the exchange did not create an enforceable contract because MotionMobs’ response was a counteroffer containing indefinite terms that were never accepted by the defendants. The Court emphasized that a valid contract requires definite material terms and mutual assent, which were lacking in this instance. Accordingly, the Supreme Court of Alabama reversed the circuit court’s judgment and remanded the case for further proceedings. View "iWTNS, Inc. v. MotionMobs, LLC" on Justia Law

Hexagon US Federal, Inc. ("HexFed") leased a portion of a building, which was later sold to CBS Holdings, LLC. A dispute arose regarding the lease's renewal, leading HexFed to file a lawsuit against CBS Holdings for breach of lease. CBS Holdings counterclaimed. The Madison Circuit Court ruled in favor of HexFed on all claims and awarded costs and attorney fees to be determined later. CBS Holdings appealed, and the Supreme Court of Alabama affirmed the trial court's judgment, including the award of costs and attorney fees.After an evidentiary hearing, the Madison Circuit Court awarded HexFed $174,987.45 in costs and attorney fees. CBS Holdings appealed, arguing that HexFed's application for attorney fees was inadequately supported due to redacted descriptions of legal work and that the trial court's order lacked sufficient detail for meaningful appellate review.The Supreme Court of Alabama reviewed the case and agreed with CBS Holdings. The court found that HexFed's heavily redacted invoices did not provide enough information to determine the reasonableness and necessity of the attorney fees. The court emphasized that a trial court's order must allow for meaningful appellate review by articulating the decisions made, the reasons supporting those decisions, and how the attorney fee was calculated, considering all the Peebles factors.The Supreme Court of Alabama reversed the trial court's order and remanded the case for HexFed to provide adequate support for its application for costs and attorney fees. The trial court was instructed to accept any necessary information or evidence to confirm the requested attorney fees and to enter a detailed order showing how it calculated the amount awarded and how it considered the Peebles factors. View "CBS Holdings, LLC v. Hexagon US Federal, Inc." on Justia Law