Justia Alabama Supreme Court Opinion Summaries

Nicholas Hoffman, a former firefighter for the City of Birmingham, was released from duty in 2022 due to a medical condition. He applied for both extraordinary and ordinary disability benefits from the City of Birmingham Retirement and Relief System, but the Board of Managers denied his claims. Hoffman received notice of the denial on December 28, 2022. On March 10, 2023, he filed a petition for a writ of mandamus in the Jefferson Circuit Court to review the Board's decision.The Jefferson Circuit Court dismissed Hoffman's petition, citing improper service of process. Hoffman initially attempted service by certified mail, but the return receipts were signed by an employee of the City's finance department, not an authorized agent of the respondents. Hoffman then attempted service through the sheriff's office, but the summons was accepted by a city clerk, not the mayor or an authorized agent. The trial court granted the respondents' motion to quash service and ordered Hoffman to perfect service within 30 days. When Hoffman failed to do so to the court's satisfaction, the court dismissed the case with prejudice.The Supreme Court of Alabama reviewed the case and found that Hoffman had made diligent efforts to serve the respondents and had not exhibited a clear record of delay, willful default, or contumacious conduct. The court held that the trial court exceeded its discretion in dismissing the case with prejudice. The Supreme Court of Alabama reversed the trial court's judgment and remanded the case for further proceedings. View "Hoffman v. City of Birmingham Retirement and Relief System" on Justia Law

Keith Edward Myers posted a negative online review about the legal services provided by Jerry M. Blevins. Blevins, representing himself, sued Myers in the Elmore Circuit Court for defamation per se, invasion of privacy, wantonness, and negligence, seeking damages and injunctive relief. The court sealed the case record and, after unsuccessful attempts to serve Myers, allowed service by publication. Myers did not respond, leading to a default judgment awarding Blevins $500,000 in compensatory damages, $1.5 million in punitive damages, and a permanent injunction against Myers.Myers later appeared in court, filing motions to unseal the record and set aside the default judgment, arguing improper service and venue, among other issues. The trial court unsealed the record but did not rule on the motion to set aside the default judgment. Myers filed for bankruptcy, temporarily staying proceedings, but the bankruptcy case was dismissed. Myers then filed a notice of appeal and a renewed motion to stop execution on his property, which the trial court granted, staying execution pending the appeal.The Supreme Court of Alabama reviewed the case. The court dismissed Myers's direct appeal as untimely regarding the default judgment and premature concerning the Rule 60(b) motion, which remained pending in the trial court. The court also dismissed Myers's challenge to the sealing of the record, noting that the trial court had already unsealed it, rendering the issue moot.Blevins's petition for a writ of mandamus to vacate the trial court's order quashing writs of execution was also dismissed as moot. The Supreme Court's resolution of the direct appeal allowed trial court proceedings, including Blevins's execution efforts, to resume, thus granting Blevins the relief he sought. View "Myers v. Blevins" on Justia Law

The case involves a dispute over the ownership of real property following the death of Billy Skidmore. Billy died intestate in July 2015, leaving behind two sons, John and Billy Jr. The Marshall Probate Court awarded John letters of administration over Billy's estate. Billy Jr. later filed a claim asserting his entitlement to an equal share of the estate. John filed an inventory listing the estate's assets, including a one-third interest in a commercial building. Billy Jr. moved to compel a final settlement, leading to a hearing where John admitted to commingling estate rental proceeds with his personal funds. The probate court subsequently appointed Billy Jr. as the successor administrator and authorized him to list the estate's real property for sale.John discovered a 2004 deed conveying the property to him and Billy as joint tenants with rights of survivorship, which he recorded in July 2023. Despite this, the probate court declared the property to be owned one-third each by John, Jenna (John's ex-wife), and Billy's estate. John removed the administration of the estate to the Marshall Circuit Court and filed a motion to alter, amend, or vacate the probate court's judgment. The circuit court denied his motion, leading John to appeal to the Supreme Court of Alabama.The Supreme Court of Alabama held that the Marshall Probate Court lacked jurisdiction to adjudicate the dispute over the title to the real property. The court emphasized that probate courts do not have the authority to determine equitable issues or administer equitable remedies, such as setting aside a recorded deed. Consequently, the Supreme Court reversed the circuit court's order and remanded the case for further proceedings consistent with its opinion. View "Skidmore v. Skidmore" on Justia Law

Radiance Capital Receivables Twelve, LLC ("Radiance") appealed a judgment from the Henry Circuit Court in favor of Bondy's Ford, Inc. ("Bondy's"). Radiance had garnished the wages of David Sherrill, who worked for Bondy's. Bondy's stopped paying on the garnishment, claiming Sherrill had left its employment, but continued to pay for Sherrill's services through a company created by Sherrill's wife. Radiance argued that Bondy's should still comply with the garnishment by withdrawing funds owed for Sherrill's services.The Henry Circuit Court had initially entered a garnishment judgment in favor of SE Property Holdings, LLC, which was later substituted by Radiance. Bondy's reported Sherrill's employment termination in September 2019, two months after the required notice period. Radiance filed a motion for judgment against Bondy's, arguing that Sherrill continued to provide services to Bondy's through his wife's company, KDS Aero Services, LLC. Bondy's responded with a motion to dismiss, claiming Sherrill was an independent contractor. The trial court granted Bondy's motion to dismiss and denied Radiance's motion.The Supreme Court of Alabama reviewed the case de novo. The court found that genuine issues of material fact existed regarding whether Bondy's payments to KDS Aero Services were actually owed to Sherrill. The lack of a contract or invoices between Bondy's and KDS Aero Services, coupled with inconsistencies in Sherrill's representations about his employment and residence, suggested potential fraud or misuse of corporate form to hide funds. The court reversed the trial court's judgment and remanded the case for further proceedings, emphasizing that neither party had met the burden for summary judgment. View "Radiance Capital Receivables Twelve, LLC v. Bondy's Ford, Inc." on Justia Law

The City of Helena appealed a decision by the Shelby Circuit Court that allowed the Pelham Board of Education (PBE) to acquire, develop, and use a piece of real property within Helena's corporate limits for an athletic field and parking lot to serve Pelham High School students. The property, purchased by the PBE in 2021, is adjacent to Pelham High School but located within Helena. Helena argued that the PBE lacked the authority to construct and operate school facilities outside Pelham's corporate limits and that the project violated Helena's zoning ordinance.The Shelby Circuit Court ruled in favor of the PBE, stating that city zoning ordinances do not apply to governmental functions performed by a government body. The court found that the PBE's construction of the athletic field was a governmental function related to public education, which is exempt from local zoning regulations. Helena appealed, arguing that the PBE's actions were not authorized under Alabama Code § 16-11-9 and that the project did not comply with Helena's zoning ordinance.The Supreme Court of Alabama affirmed the circuit court's decision. The court held that § 16-11-9 does not restrict a city board of education's powers to the geographic boundaries of the city it serves. The court also concluded that the PBE's construction and operation of the athletic field constituted a governmental function related to public education, which is exempt from municipal zoning ordinances. Therefore, Helena's zoning ordinance could not be enforced against the PBE's project. The court affirmed the circuit court's order, allowing the PBE to proceed with the development and use of the property. View "City of Helena v. Pelham Board of Education" on Justia Law

The case revolves around a dispute over a property deed. Earnest Coprich and Bessie Elizabeth Jones, who have known each other for about 50 years, disagreed over the terms of a property sale. Coprich claimed that he sold his residence to Jones for $15,000, while Jones contended that the sale price was $10,000. After Jones moved into the property and made several improvements, Coprich filed a complaint seeking to set aside the deed. He alleged that he was mentally incompetent at the time of signing the deed and that he was coerced and defrauded by Jones. Jones denied these allegations and asserted that she had purchased the property and occupied it since the transaction.The Montgomery Circuit Court, after a bench trial, ruled in favor of Jones. The court found that Coprich failed to present sufficient evidence to prove his incompetence or that Jones had committed fraud or misrepresentation. Coprich's postjudgment motion to vacate the order was summarily denied by the court. Coprich then appealed to the Court of Civil Appeals, which transferred the appeal to the Supreme Court of Alabama due to lack of appellate jurisdiction.The Supreme Court of Alabama, however, determined that the Court of Civil Appeals should have jurisdiction over the case. The court noted that the case is a "civil case" as defined by § 12-3-10 and that the "amount involved" does not exceed the jurisdictional threshold of $50,000. Therefore, the Supreme Court transferred the appeal back to the Court of Civil Appeals. View "Coprich v. Jones" on Justia Law

David McGilvray, a former investigator for the Alabama Board of Medical Examiners (the Medical Board), was terminated for sending a sexually explicit email to his coworkers. Following his termination, the Medical Board requested the Local Government Health Insurance Board (the Insurance Board) to cancel McGilvray's health-insurance benefits. McGilvray, claiming he had retired before the Medical Board ratified his termination, sought retiree-health-insurance benefits. His request was denied by the Insurance Board on the grounds that he had been fired for cause and had not retired.McGilvray filed two lawsuits in an attempt to obtain retiree-health-insurance benefits. The first lawsuit was against the executive director of the Medical Board and the CEO of the Insurance Board. The Montgomery Circuit Court entered summary judgment against him, ruling that his claims were time-barred. In the second lawsuit, which is the subject of this appeal, McGilvray sued the executive director of the Medical Board and the members of the Medical Board in both their official and individual capacities. The Montgomery Circuit Court dismissed this suit based on the doctrines of State immunity and res judicata.The Supreme Court of Alabama affirmed the lower court's decision. The court found that McGilvray's breach-of-contract claim, seeking damages from the Medical Board defendants in their official capacities, was barred by State immunity. Furthermore, the court ruled that all of his other claims were barred by res judicata, as they arose from the same set of facts as his claims in the prior action: the termination of his employment and the Insurance Board's denial of his request for retiree-health-insurance benefits. View "McGilvray v. Perkins" on Justia Law

This case involves a contractual dispute between Alabama Plating Technology, LLC (APT) and Georgia Plating Technology, LLC (GPT), DVEST, LLC, and Jin Kim. The dispute arose from an asset-purchase agreement for a brake-plating plant. After the purchase, APT claimed indemnity from the sellers for environmental issues, unpaid accounts payable, and certain inoperable assets, alleging these were retained liabilities or breaches of warranties by the sellers. The sellers sued APT for breach of contract due to setoff of losses against annual installment payments.The trial court found in favor of APT regarding the environmental issues and unpaid accounts payable, but sided with the sellers on the inoperable-assets claim. It also rejected APT's claim for attorneys' fees and legal expenses. Both parties appealed.The Supreme Court of Alabama reversed the trial court's judgment denying APT relief on its inoperable-assets claim and its claim for attorneys' fees and legal expenses. It affirmed the trial court's judgment granting APT relief on its environmental-issues and unpaid-accounts-payable claims, and the denial of the sellers' request to accelerate the remaining installment payments owed to them by APT. View "Alabama Plating Technology, LLC v. Georgia Plating Technology, LLC" on Justia Law

The case involves Stacy G. Coats and Kendall Coats (the plaintiffs) who filed a private right-of-way condemnation case against Sandra F. Ayers, Tommy J. Ayers, and J. Jason Ayers (the defendants). The plaintiffs sought a right-of-way across the defendants' property to access their own landlocked properties. The properties in question include several parcels of land, some of which are low-lying wetlands often flooded and used for hunting and fishing. A private dirt road, referred to as the "farm road," crosses the defendants' property and has been historically used by the plaintiffs and their predecessors to access their properties.The Tuscaloosa Probate Court initially granted the plaintiffs a right-of-way across the defendants' property, concluding that the plaintiffs' property was landlocked. The defendants appealed this decision to the Tuscaloosa Circuit Court. The defendants argued that the plaintiffs' property was no longer landlocked due to inheritance of additional land that touched a public road. The Circuit Court agreed with the defendants, granting a summary judgment in their favor on the grounds that the plaintiffs' property was no longer landlocked and they had reasonable access to their property from a public road.The Supreme Court of Alabama reversed the decision of the Tuscaloosa Circuit Court. The Supreme Court found that there was a genuine issue of material fact regarding whether the plaintiffs have an existing, reasonable means to access their landlocked property. The court noted that the plaintiffs had presented substantial evidence indicating that they could not travel from the public road across their property to access their landlocked property. The court concluded that the plaintiffs had permission to cross an intervening property, and thus there was no requirement for them to seek a right-of-way over it. The case was remanded for further proceedings. View "Coats v. Ayers" on Justia Law

Joe Iskra and Rani Singh, the plaintiffs, entered into a contract to purchase a house from Kenneth Vinoski. Before closing, they hired a home inspection service that discovered a leak in the attic. The plaintiffs requested Vinoski to repair the leak before the sale, and Vinoski contracted Bear Roofing, LLC, the defendant, for the repair. The plaintiffs alleged that they were intended third-party beneficiaries of the contract between Vinoski and Bear, and that Bear breached the contract and an associated express warranty. They also claimed that Bear negligently performed the contracted repairs.The Jefferson Circuit Court entered a summary judgment in favor of Bear, ruling that the plaintiffs were not intended third-party beneficiaries of the contract between Vinoski and Bear. The court reasoned that the plaintiffs failed to provide substantial evidence that Bear intended to bestow a direct benefit to them at the moment the contract was formed. The court also noted that the contract did not mention or refer to the plaintiffs, and there was no evidence that Bear intended for anyone other than Vinoski to receive the benefit of its work performance.On appeal, the Supreme Court of Alabama reversed the trial court's decision and remanded the case for further proceedings. The Supreme Court found that the plaintiffs presented evidence showing a genuine issue of material fact regarding whether Bear intended to bestow a direct benefit upon them. The court also found that the plaintiffs presented evidence demonstrating a genuine issue of material fact regarding whether they were covered under Bear's warranty. Lastly, the court found that the plaintiffs presented evidence showing that they had relied to their detriment on Bear's performance in repairing the leak, and that Bear had known that it had been hired to repair a leak noted in an inspection report prepared in contemplation of the imminent sale of the house. Therefore, the trial court erred in entering a summary judgment in favor of Bear on the plaintiffs' negligence claim. View "Iskra v. Bear Roofing, LLC" on Justia Law