Justia Alabama Supreme Court Opinion Summaries

A circuit court entered a judgment divorcing Jason Grimmett from April Grimmett on the ground of adultery by Jason, and divided the couple's marital property. The Court of Civil Appeals affirmed the judgment without an opinion, and Jason petitioned the Alabama Supreme Court for certiorari review. The Supreme Court issued the writ to examine, among other things, a potential conflict in the law regarding whether adultery committed after a party files for divorce was a ground for divorce. Because the language chosen by the Legislature, specifying adultery as a ground for divorce, did not limit this ground to prefiling conduct, and because the Supreme Court's early cases distinguishing between prefiling and postfiling adultery had to be read in light of the procedural restrictions of equity practice under which they were decided, the Court affirmed the circuit court's judgment. View "Ex parte Jason Grimmett." on Justia Law

The Alabama Space Science Exhibit Commission d/b/a U.S. Space & Rocket Center ("ASSEC") filed suit against Space Race, LLC ("Space Race"), seeking to avoid an arbitration award entered in favor of Space Race and against ASSEC by an arbitration panel in New York. In July 2016, Space Race agreed to produce an animated series for ASSEC aimed at promoting the interest of children in space exploration and science. The series was to be created and released to the public over a three-year period. In exchange, ASSEC agreed to compensate Space Race with funds ASSEC would receive from a grant from the National Aeronautics and Space Administration ("NASA"), which had contracted with ASSEC to provide funding for the series. The compensation was to be paid to Space Race annually as the series episodes were created during the three-year contract term. The parties' agreement provided that it "shall be governed" by Alabama law. Space Race produced the series before the contract term expired, but ASSEC failed to pay the amount owed for the last year of the series. Space Race claimed that ASSEC still owed Space Race approximately $1.3 million when the contract term expired. The parties' agreement contained an arbitration provision. In December 2017, after being notified by ASSEC that it would no longer make payments to Space Race because the grant from NASA had been terminated, Space Race commenced arbitration proceedings against ASSEC in New York. Space Race moved to dismiss ASSEC's Alabama action, asserting that a New York court had already entered a final judgment confirming the arbitration award. The Alabama trial court denied Space Race's motion to dismiss, and Space Race petitioned the Alabama Supreme Court for a writ of mandamus directing the trial court to dismiss ASSEC's action. Because the New York judgment confirming the arbitration award against ASSEC was entitled to full faith and credit and res judicata effect, the Supreme Court granted Space Race's mandamus petition. The trial court was directed to vacate its order denying Space Race's motion to dismiss and to enter an order granting that motion. View "Ex parte Space Race, LLC." on Justia Law

The United States Court of Appeals for the Eleventh Circuit certified five questions to the Alabama Supreme Court on whether state law permitted WM Mobile Bay Environmental Center, Inc. ("WM Mobile"), a judgment creditor, to execute on certain real property owned by the City of Mobile Solid Waste Authority ("the Authority"), a public solid-waste-disposal authority established pursuant to the Alabama Solid Waste Disposal Authorities Act ("the Act"). WM Mobile sued the Authority, alleging that the Authority breached various provisions of a contract between WM Mobile and the Authority for the operation of a landfill (the 'Landfill') owned by the Authority. After a jury trial, WM Mobile obtained a judgment against the Authority totaling $6,034,045.50. To partially satisfy its judgment, WM Mobile asought a writ of execution against a 104-acre parcel of land (the 'West Tract') owned by the Authority that sat adjacent to the Landfill. The Authority purchased the West Tract in 1994 for the future potential expansion of the Chastang Landfill. At the time of the lawsuit, the expansion had not been needed. The Authority moved to quash WM Mobile's request for a writ of execution, asserting, among other things, that Alabama law prohibited execution on the West Tract because that land was owned by the Authority for public use. The district court agreed with the Authority and granted its motion to quash. The Supreme Court concluded: (1) property owned by a solid waste disposal authority did not belong to a county or municipality pursuant to section 6-10-10 Ala. Code 1975; (2) a creditor of such a corporation [like the Authority] cannot subject to attachment, execution or other legal process such of its property as it needs in the performance of its corporate functions and in carrying out of its franchise obligations towards the public; and (3) with regard to what standards were to be used in applying the common-law exemption to attaching a public corporation's property, the Supreme Court noted that the key inquiry was whether the property at issue was owned or used for public purposes. In its responses, the Supreme Court answered the federal district court's first, fourth and fifth questions; the second and third questions were declined. View "WM Mobile Bay Environmental Center, Inc. v. City of Mobile Solid Waste Authority" on Justia Law

Ilka Porter and Lina Louise Porter, through her mother and next friend, Ilka Porter, appealed a probate court order that concluded Sean Porter was married to Alexis Campbell Porter at the time of his death, and appointing Alexis Campbell Porter as administratrix of his estate. The question presented by these appeals was one of first impression in Alabama: Whether the death of a party to a marriage, after a marriage document is executed but before the marriage document is recorded, invalidates the marriage for failure to comply with the registration requirements of section 22-9A-17, Ala. Code 1975. The Alabama Supreme Court concluded that it did not, affirming the probate court's order. View "Porter v. Estate of Porter" on Justia Law

Brett Deslonde appealed the grant of summary judgment entered in favor of Nationstar Mortgage, LLC, doing business as Mr. Cooper ("Nationstar"), and The Bank of New York Mellon, as trustee for Nationstar Home Equity Loan Trust 2007-C ("BNYM"), on Deslonde's claim seeking reformation of a loan-modification agreement on the ground of mutual mistake. In December 2006, Deslonde purchased real property in Fairhope, Alabama with a loan from Nationstar. Deslonde subsequently defaulted on his mortgage payments and applied for a loan modification through Nationstar's loss-mitigation program. By letter dated February 2014, Nationstar notified Deslonde that he had been approved for a "trial period plan" under the federal Home Affordable Modification Program ("the federal program"). Under the federal program, Deslonde was required to make three monthly trial payments in the amount of $1,767.38 and to submit all required documentation for participation in the program, including an executed loan-modification agreement. In July 2014, Nationstar informed Deslonde that his request for a loan modification under the federal program had been denied because he had not returned an executed loan-modification agreement or made the trial payments. That letter informed Deslonde that there were other possible alternatives that might be available to him if he was unable to make his regular loan payments. Deslonde submitted a second application package for loss mitigation in October 2014. Under the executed modification agreement from the second application, Deslonde made monthly payments sufficient to cover only interest and escrow charges on the loan. The loan-modification period, however, expired in November 2016, at which time the monthly payments reverted to the premodification amount so as to include principal on the loan. After the loan-modification period expired, Deslonde made three additional monthly payments, but he then ceased making payments altogether. In an attempt to avoid foreclosure, Deslonde filed a complaint against Nationstar and BNYM in the Baldwin Circuit Court ("the trial court"), requesting a temporary restraining order enjoining foreclosure of the mortgage, a judgment declaring the parties' rights under the executed modification agreement, and reformation of the executed modification agreement on the ground of mutual mistake. Finding that the trial court did not err in granting summary judgment in favor of Nationstar and BNYM, the Alabama Supreme Court affirmed. View "Deslonde v. Nationstar Mortgage, LLC, d/b/a Mr. Cooper et al." on Justia Law

In July 2009, JPMC Specialty Mortgage, LLC ("JPMC"), foreclosed on a property in Grand Bay, Alabama that had once been owned by the parents of Marian S.A. Tipp. Since that time, Tipp filed one lawsuit after another seeking to unravel that foreclosure and gain ownership of the property. After concluding that Tipp's claims in her most recent lawsuit were barred by the doctrine of res judicata, the applicable statutes of limitations, and Alabama's abatement statute, the trial court entered summary judgment in favor of JPMC. Because of Tipp's history of litigation against JPMC, the trial court also entered a permanent injunction that prohibited her from initiating any further proceedings related to the foreclosure of the Grand Bay property without first obtaining permission from that court. Tipp appealed. Finding no reversible error, the Alabama Supreme Court affirmed the judgment. View "Tipp v. JPMC Specialty Mortgage, LLC" on Justia Law

Sandra Gleason filed suit against Charles Halsey and Jim McDonough d/b/a Jim McDonough Home Inspection ("McDonough"), seeking to recover for damage that Gleason allegedly incurred as a result of defendants' allegedly negligent and/or fraudulent conduct associated with Gleason's purchase of a house from Halsey and McDonough's inspection of the house. Although Gleason's claims against Halsey and McDonough involve different legal theories, the issue underlying the claims was essentially the same: whether the house was inspected. The issue underlying Gleason's claims against Halsey was whether McDonough's inspection of the house could be credited to Gleason for purposes of determining whether Gleason may assert an argument under the health or safety exception to the doctrine of caveat emptor; the issue underlying Gleason's claims against McDonough appeared to be whether McDonough owed Gleason a duty in inspecting the house or in consulting with Gleason as she personally inspected the house. The Alabama Supreme Court found that Gleason's claims against Halsey, the judgment on which was certified as final under Rule 54(b), and Gleason's claims against McDonough that remain pending in the circuit court "are so closely intertwined that separate adjudication would pose an unreasonable risk of inconsistent results." As a result, the Court concluded that the circuit court exceeded its discretion in certifying the June 23, 2021, order granting Halsey's summary-judgment motion as final. The Court therefore dismissed the appeal. View "Gleason v. Halsey" on Justia Law

Capitol Farmers Market, Inc., appealed a circuit court order entered in favor of Angie and Russell Ingram, enforcing certain restrictive covenants on property owned by Capitol Farmers Market that abutted property owned by the Ingrams. After review, the Alabama Supreme Court determined the trial court did not err in upholding the restrictive covenants found in the respective property declarations. Accordingly, judgment was affirmed. View "Capitol Farmers Market, Inc. v. Ingram" on Justia Law

David Bronner, secretary-treasurer of the Public Education Employees' Health Insurance Plan ("PEEHIP"), and individual members of the Board of Control of PEEHIP ("the PEEHIP Board"), the remaining defendants in this action (collectively, "defendants"), appealed the grant of summary judgment entered in favor of the plaintiffs and members of a purported class, who were all active public-education employees and PEEHIP participants married to other active public-education employees and PEEHIP participants and who had dependent children. Before October 1, 2010, all public-education employees participating in PEEHIP earned a monthly "allocation" or benefit, which could be used to obtain certain coverage alternatives under PEEHIP. In May 2010, the PEEHIP Board voted to eliminate "the combining allocation program" and to phase in a new premium rate structure ("the 2010 policy"), which required a public-education employee married to another public-education employee to gradually begin paying the same monthly premiums for family hospital-medical coverage that other PEEHIP participants were required to pay. In May 2014, the original named plaintiffs, individually and on behalf of a class of similarly situated individuals, filed a purported class action against the defendants, among others, pursuant to 42 U.S.C. 1983. In their complaint, the original named plaintiffs sought a judgment declaring that the 2010 policy was unconstitutional under the Due Process Clause and the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution because, they claimed, the 2010 policy denied them and the members of the purported class a benefit for the payment of insurance accorded every other PEEHIP participant. The original named plaintiffs sought an order enjoining the defendants from denying them and the members of the purported class the use of that benefit, which, they claimed, would permit them and the members of the purported class to obtain family coverage at no cost. The defendants thereafter moved for a summary judgment, which the trial court denied. The Alabama Supreme Court reversed, finding nothing to indicate that the defendants intended to single out the public-education plaintiffs for disparate treatment under the 2010 policy. Accordingly, the Court concluded the 2010 policy was neither arbitrary nor discriminatory and that it did not violate either the Equal Protection Clause or the Due Process Clause of the Fourteenth Amendment to the United States Constitution. View "Bronner, et al. v. Barlow et al." on Justia Law

Several entities that owned or operated hospitals in Alabama ("plaintiffs") filed suit against manufacturers of prescription opioid medications, distributors of those medications, and retail pharmacies ("defendants"), alleging that defendants' marketing or selling of the medications resulted in an epidemic of opioid abuse in Alabama. Plaintiffs sought to recover unreimbursed medical expenses incurred in treating individuals with opioid-related medical conditions. Among other theories of liability, plaintiffs asserted that defendants had created a public nuisance in the form of the epidemic. The trial court entered a case-management order directing the parties to try each of plaintiffs' causes of action separately. The public-nuisance claim was to be tried first and is itself to be bifurcated into two separate trials. The first trial on the public-nuisance claim was to involve "liability," and the second trial was to involve "special damage." Defendants, asserting that the trial court had erred in bifurcating the public-nuisance claim, petitioned the Alabama Supreme Court for a writ of mandamus directing the trial court to vacate the relevant portion of the case-management order. The Supreme Court granted the writ: "conducting a trial on the issue of the defendants' 'liability' for a public nuisance and a second trial on 'special damage' neither avoids prejudice nor furthers convenience, expedition, or economy. We can only conclude that the trial court exceeded its discretion. We therefore grant the defendants' petition and issue a writ of mandamus." View "Ex parte Endo Health Solutions Inc. et al." on Justia Law