Justia Alabama Supreme Court Opinion Summaries

Shirley Temple Carr Ralph ("Mrs. Ralph") executed a will naming Philip Kelsoe ("the proponent") the executor and sole beneficiary of her estate. estate. Mrs. Ralph's sister, Nel Brock, contested the will, arguing that Mrs. Ralph had lacked the mental capacity to execute the will and that the will was the product of undue influence on the part of the proponent. The Morgan Circuit Court entered a summary judgment in favor of the proponent, and Brock appealed. The Alabama Supreme Court reversed, finding the circumstances surrounding the timing of the execution of the will, the proponent's dominion over the will, and Dr. Campbell's testimony regarding Mrs. Ralph's deteriorating physical and mental state, a jury could have inferred the proponent was unduly active in the procurement of the will. Dr. Campbell testified that, around the time Mrs. Ralph executed the will, her health had deteriorated both mentally and physically, she was under the influence of "mind-altering" medications, and she was easily susceptible to being taken advantage of. Accordingly, Brock presented substantial evidence of all the elements necessary to submit her claim of undue influence to a jury. The matter was remanded for further proceedings. View "Brock v. Kelsoe" on Justia Law

Plaintiffs Barry Munza, Larry Lewis, and Debbie Mathis appealed a circuit court order dismissing their complaint seeking certain injunctive relief and challenging a proclamation issued by Governor Kay Ivey requiring the use of facial coverings in certain circumstances, as outlined in an order issued by Dr. Scott Harris, the State Health officer, to slow the spread of COVID-19. The Alabama Supreme Court concluded plaintiffs lacked standing to bring their complaint seeking injunctive relief regarding the July 15 proclamation adopting the amended health order that, among other things, required masks or facial coverings to be worn in certain circumstances. Because the Supreme Court determined plaintiffs lacked standing, any discussion of remaining issues was pretermitted. View "Munza, et al. v. Ivey, et al." on Justia Law

Encompass Health Corporation, formerly known as HealthSouth Corporation ("HealthSouth"), petitioned the Alabama Supreme Court for a writ of mandamus to direct the the trial court to vacate an order entered June 17, 2020, which amended a February 26, 2016 dismissing with prejudice several defendants in the underlying action, to dismiss those defendants without prejudice. The underlying action was initiated in March 2003 by Steven Nichols, a former employee of HealthSouth and a holder of HealthSouth stock; Nichols initially sued HealthSouth, Richard Scrushy, Weston Smith, William Owens, and the accounting firm Ernst & Young, alleging fraud and negligence. The action was delayed for eleven years "for a variety of reasons," during which Nichols filed several amended complaints. By his eighth amended complaint, only HealthSouth was named as a defendant. At the same time, Nichols filed a "motion to dismiss [the] individual defendants without prejudice." In that motion, Nichols "specifically reserve[d] all claims against HealthSouth ... based upon respondeat superior and vicarious liability theories." The trial court entered an order providing that the eighth amended complaint controlled, that HealthSouth was the only remaining defendant in the action, and that there were now no claims asserted against any of the other defendants named in the previously filed complaints. HealthSouth then moved to dismiss the eighth amended complaint, arguing, among other things, that "the claims asserted in that complaint were derivative in nature rather than direct and were therefore due to be dismissed" based on Nichols's failure to comply with the demand-pleading requirements of Rule 23.1, Ala. R. Civ. On this case's first trip to the Alabama Supreme Court, the Court held the claims in the eighth complaint related back to the original, and thus, were not barred by the statute of limitations. After remand and further discovery, HealthSouth again moved to dismiss, arguing that Nichols' claims were based on representations made by a former agent, and that agent was dismissed with prejudice earlier in these proceedings. In response, Nichols asked the trial court to amend its order to reflect he had specifically reserved his right to proceed against HealthSouth. HealthSouth's motion was ultimately denied, and it petitioned the Supreme Court for mandamus relief. The Supreme Court determined the trial court violated the Supreme Court's mandate when it amended a February 2016 order that dismissed the individual defendants with prejudice. Therefore, the Court concluded HealthSouth demonstrated a clear legal right to mandamus relief. View "Ex parte Encompass Health Corporation." on Justia Law

Lawrence Taylor appealed the grant of summary judgment entered in favor of Charles Hanks in Taylor's will contest. Taylor challenged the will of his father, Billy Lee Hite, alleging, among other things, that Hite had lacked testamentary capacity when he made the will, which did not mention Taylor. Because the Alabama Supreme Court concluded that a genuine issue of material fact existed regarding whether Hite had testamentary capacity, judgment was reversed and the matter remanded for further proceedings. View "Taylor v. Hanks" on Justia Law

Plaintiffs Crag Dyas and Dyas, LLC appealed a circuit court's orders disposing of some of their claims against some of the defendants below. Because those orders did not constitute a valid, final judgment that would support an appeal, the Alabama Supreme Court dismissed this appeal. View "Dyas v. Stringfellow et al." on Justia Law

Lonas Goins was injured when a train locomotive that he was operating collided with a garbage truck at a railroad intersection. Goins sued the owner and the driver of the truck. After a five-day trial, a jury found in favor of Goins and awarded him damages. Dissatisfied with the jury's damages award, Goins appealed the judgment, arguing that the trial court committed multiple errors that warranted a new trial. Finding no reversible error, the Alabama Supreme Court rejected Goins's arguments and affirmed the judgment. View "Goins v. Advanced Disposal Services Gulf Coast, LLC" on Justia Law

Shirley English sued Murphy Oil USA, Inc., after she slipped and fell in the restroom of a Murphy Oil gas station. Murphy Oil moved for summary judgment, but the trial court denied the motion. After a bench trial, the court entered a judgment in favor of English. The trial court made no findings of fact during the trial and instead took the matter under consideration after inviting the parties to submit briefs. One day after the briefing deadline had passed, the trial court entered a judgment in favor of English and awarded her compensatory damages in the amount of $125,000. The trial court did not make any written factual findings as a part of its judgment. It appeared from the record that Murphy Oil did not move for a new trial or for judgment as a matter of law, and it did not otherwise challenge the sufficiency of the evidence before it appealed to the Alabama Supreme Court. Murphy Oil argued on appeal that: (1) the trial court erred by denying its summary-judgment motion; (2) English offered no evidence at trial to sustain a judgment holding it liable for negligence; and (3) the trial court erred by admitting evidence of medical expenses that was unsupported by expert testimony. The Supreme Court determined none of Murphy Oil's arguments provided a ground for reversing the trial court judgment: Murphy Oil did not establish the Supreme Court should disregard the general rule against reviewing a trial court's denial of a summary- judgment motion after a trial on the merits. And its argument about the sufficiency of the evidence at trial was not properly before the Supreme Court. Finally, based on the record before it, the Supreme Court could not say that the trial court erred by admitting evidence of English's medical expenses. View "Murphy Oil, USA, Inc. v. English" on Justia Law

Chris and Suzanne Moore, as parents and next friends of Sydney Moore, a minor, appealed the grant of summary judgment entered in favor of Pamela Tyson and Jennifer Douthit, two employees of the Huntsville City Board of Education ("the Board"), with regard to negligence and wantonness claims asserted against Tyson and Douthit by the Moores arising from injuries suffered by Sydney at her elementary school. Tyson was employed by the Board as a teacher at Goldsmith-Schiffman Elementary School. Douthit was employed as the principal of the school. Sydney was enrolled at the school as a third-grade student in Tyson's class. Tyson left the students unsupervised in the classroom while she went to the restroom. During that time, Sydney and another student in the class left their seats, and, according to Sydney, the other student caused her to fall and hit her head and face on a counter in the classroom. Sydney suffered injuries from her fall, including fractures of her left orbital bone, her eye socket, and her nose and entrapment of her eye. Sydney was admitted for treatment at a hospital and underwent surgery as a result of the injuries. THe Alabama Supreme Court determined the Moores did not demonstrate the trial court erred in entering summary judgment in favor of Tyson and Douthit based on immunity. Accordingly, the Court affirmed the trial court's judgment. View "Moore v. Tyson" on Justia Law

Defendant Allstate Property and Casualty Insurance Company ("Allstate"), appealed a circuit court's order granting the posttrial motion of the plaintiff, Doyle Harbin, which sought the imposition of sanctions based on Allstate's purported violation of a pretrial mediation order. In 2015, Harbin was injured as the result of a motor-vehicle accident that he alleged was caused by Irvin Stewart. Harbin subsequently filed a complaint in the trial court asserting a negligence claim against Stewart. In the same complaint, Harbin also named Allstate, Harbin's automobile insurance carrier, as a defendant and sought to recover uninsured/underinsured-motorist ("UIM") benefits under his Allstate policy. Following Stewart's dismissal, Harbin, without opposition from Allstate, requested that the scheduled trial date be continued and the matter referred to mediation. Unable to reach a settlement, the matter proceeded to trial. A jury returned a $690,000 verdict in Harbin's favor. Approximately two weeks later, Harbin filed a "Motion for Entry of Judgment and Motion for Sanctions," essentially contending Allstate in bad faith failed to abide by the Order which set the Court-ordered mediation in which Allstate had agreed to participate. The motion requested Allstate pay Harbin's trial-related attorneys' fees. The Alabama Supreme Court found the evidence failed to show Allstate violated the trial court's mediation order, thus it exceeded its discretion by issuing Harbin's requested sanctions. The Court therefore reversed the portion of the trial court's order imposing sanctions exceeding Harbin's request for costs and fees totaling $57,516.36, and remanded this matter for further proceedings. View "Allstate Property & Casualty Ins. Co. v. Harbin" on Justia Law

The State appealed a circuit court order denying its request for a preliminary injunction against TY Green's Massage Therapy, Inc., Yuping Tang, and Jiao Liu a/k/a Serena Tang (collectively, "the defendants"). In September 2018, police received an anonymous tip that a customer had gone into the defendants' Madison location for a massage and that he had been touched inappropriately. As a result, the police started an investigation of TY Green's Massage Therapy that included, among other things, sending multiple men into the business locations undercover to get massages and conducting surveillance of the business locations and of the houses where the employees of the business were housed. During the investigation, some of the massage therapists touched clients in places they were not supposed to touch, according to Board of Massage Therapy guidelines; that some massage therapists straddled clients and/or touched the clients with the intimate parts of their bodies and/or touched the intimate parts of the clients' bodies; and that at least one massage therapist engaged in sexual acts, including intercourse, with a client. The investigation also revealed that the massage therapists lived in houses owned by the Tangs; that the Tangs provided transportation for the therapists each day to get to the business locations where they worked; and that the therapists normally worked 12 hours per day, 7 days per week. The State filed a complaint against TY Green's Massage Therapy, Inc. that included 41 counts, including first- and second degree human trafficking, and deceptive trade practices. Among other things, the State requested injunctive and declaratory relief, damages and civil penalties. After review, the Alabama Supreme Court concluded the trial court did not exceed its discretion in denying the State's request for a preliminary injunction. Accordingly, the trial court's order was affirmed. View "Alabama v. TY Green's Massage Therapy, Inc." on Justia Law