Justia Alabama Supreme Court Opinion Summaries

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

The case involves the Mabel Amos Memorial Fund, a charitable trust established to provide financial assistance to beneficiaries seeking higher education. The plaintiffs, Megan Carmack and Leigh Gulley Manning, individually and on behalf of Carmack's minor children, and Tyra Lindsey, a minor, represented by her mother and guardian, alleged that the trustee and board members of the trust breached their fiduciary duties. They sought to remove the trustee and board members, appoint new ones, and restore the allegedly misappropriated assets of the trust. The Montgomery Circuit Court appointed a special master under Rule 53, Ala. R. Civ. P., and Attorney General Steve Marshall, who was added as a party to the underlying actions, petitioned the Supreme Court of Alabama for a writ of mandamus directing the circuit court to vacate its order appointing a special master.The Supreme Court of Alabama granted Marshall's petitions and ordered the circuit court to vacate its order referring the cases to a special master. The court found that the circuit court exceeded its discretion in referring all matters in these cases to a special master. The court noted that the referral of matters to be tried without a jury did not indicate that an "exceptional condition" necessitated the referral, and the referral of the accounting did not indicate that the accounting would prove complicated in some way. Even if the accounting was properly referred to a special master, the referral of an accounting does not justify the referral of all the other matters in the cases. View "Ex parte Marshall" on Justia Law

In 2010, Crystal Kaye Coan purchased a property in Lauderdale County, which was subject to a mortgage. Coan defaulted on the mortgage, leading to a foreclosure by Carrington Mortgage Services, LLC, the mortgage assignee. Carrington sold the property to Championship Property, LLC in an online auction in May 2018. Championship then filed an ejectment action against Coan, claiming it was the title owner and seeking possession of the property. Coan countered that the foreclosure sale was void, and therefore, Championship had not acquired the title. In January 2023, Championship requested the trial court to require Coan to deposit $2,000 per month with the court clerk pending a final ruling in the ejectment action. The trial court, over Coan's objection, ordered her to deposit $800 per month.Coan failed to deposit the court-ordered payments for March, April, and May 2023, leading Championship to move the trial court to hold her in contempt. The trial court found Coan in contempt and, as a sanction, ruled in favor of Championship on its ejectment claim, awarding it possession of the property. Coan appealed this decision.The Supreme Court of Alabama affirmed the trial court's decision to require Coan to deposit $800 per month with the court clerk, stating that the trial court had the authority to enter the escrow order. The court also affirmed the trial court's finding of contempt against Coan for failing to comply with the escrow order. However, the court reversed the trial court's sanction awarding Championship possession of the property, stating that the sanction was not appropriate given the current posture of the litigation. The case was remanded to the trial court for further proceedings consistent with the Supreme Court's opinion. View "Coan v. Championship Property, LLC" on Justia Law

A dispute arose between the Alabama-West Florida Conference ("the Conference") of the United Methodist Church, Inc. ("the UMC"), and 44 Methodist churches in the Conference ("the churches"). Amid disagreements within the UMC over issues of human sexuality, the churches sought to leave the UMC with their properties under a provision of the Book of Discipline, the governing law of the UMC. After the Conference denied the churches the ability to vote to disaffiliate under that provision, the churches asked the Montgomery Circuit Court to order the Conference to grant them that vote. The trial court dismissed the suit for lack of subject-matter jurisdiction under the Establishment Clause of the First Amendment to the United States Constitution.The Montgomery Circuit Court held an emergency hearing and heard evidence. The next day, the court dismissed the suit for lack of subject-matter jurisdiction because, according to the court, the relief that the churches requested was "ecclesiastical in nature and would require Court interference in matters of church autonomy," which would violate the Establishment Clause of the First Amendment. The churches appealed that judgment.The Supreme Court of Alabama reviewed the case and affirmed the trial court's judgment. The churches argued that the trial court erred in dismissing their suit for lack of subject-matter jurisdiction because, they said, the case presents only "civil and property issues." However, the Supreme Court of Alabama held that the churches' central claims turn entirely on the interpretation of the provision of the Book of Discipline and whether their efforts to leave the UMC were consistent with that church law. Under existing First Amendment law and the court's precedent, that interpretive issue constitutes an ecclesiastical question that courts do not have jurisdiction to decide. Therefore, the court affirmed the judgment. View "Aldersgate United Methodist Church of Montgomery v. Alabama-West Florida Conference of the United Methodist Church, Inc." on Justia Law

Nella Ruth Braswell passed away in 2014, leaving behind an estate valued at over $2,000,000, 6 cats, and 13 dogs. In her will, she provided for the care of her animals until their death, with the remaining funds to be given to The Humane Society of the United States. The Jefferson Probate Court accepted her will and appointed Marion Kristen McLeroy as the personal representative of the estate. However, The Humane Society became dissatisfied with McLeroy's management of the estate and had the estate proceeding removed from the probate court to the Jefferson Circuit Court. McLeroy objected to this move, but the circuit court refused to relinquish the case.The Humane Society and McLeroy had a working relationship initially, but it deteriorated over time. The Humane Society requested deeds to all the property Braswell had owned, as well as a formal accounting of both the estate and the Animal Trust. The Humane Society also asked the circuit court to remove McLeroy and her husband as cotrustees of the Animal Trust and to order them to reimburse the Animal Trust for any losses caused by their alleged breaches of their fiduciary duties.The Supreme Court of Alabama reviewed the case and found that once a probate court begins the final-settlement process for an estate, a circuit court cannot acquire jurisdiction over the administration of that estate. Therefore, when the probate court began the final-settlement process for Braswell's estate, the Humane Society's right to remove the proceeding to the circuit court was cut off. The Supreme Court of Alabama granted McLeroy's petition and issued a writ directing the circuit court to vacate its order consolidating the estate proceeding with the Humane Society's other action against McLeroy and her husband and to enter an order remanding the administration of Braswell's estate to the probate court. View "Ex parte McLeroy" on Justia Law

The case involves National Trust Insurance Company ("National Trust") and Whaley Construction Company, Inc. ("Whaley"). Whaley was a general contractor on a project at a Lockheed Martin facility. Smith's Inc. of Dothan ("Smith's of Dothan") was a subcontractor hired to install an HVAC system on the project, and Phoenix II Contracting, LLC ("Phoenix II"), was a subcontractor hired to install the roofing. Smith's of Dothan's subcontract with Whaley provided that Smith's of Dothan would name Whaley and Lockheed Martin as additional insureds on its liability policies. National Trust issued Smith's of Dothan a commercial-package policy and a commercial-liability umbrella policy ("the subject policies") through Harmon-DennisBradshaw, Inc. ("HDB"). Whaley and Lockheed Martin were additional insureds under the subject policies. Timothy L. Bozeman was working as a roof laborer on the Lockheed Martin project when he fell through an opening in the roof and was seriously injured. Bozeman sued Phoenix II and various fictitiously named defendants in the circuit court ("the state-court action").National Trust commenced a declaratory-judgment action in the Northern Division of the United States District Court for the Middle District of Alabama ("the federal-court action"). The complaint in the federal-court action named Smith's of Dothan, Whaley, Lockheed Martin, and the estate as respondents and included the following factual allegations: "25. A dispute has arisen as to whether Respondents Smith's [of Dothan], Whaley, and Lockheed [Martin] are entitled to a defense and indemnification as to the claims asserted in the Underlying Lawsuit. National Trust asserts that, based on the terms, conditions, and exclusions contained in the [subject] policies, Respondents Smith's [of Dothan], Whaley, and Lockheed [Martin] are not entitled to a defense in the underlying lawsuit or indemnification against settlement, award, or judgment therefrom.On April 14, 2023, Whaley filed a third-party complaint against National Trust and Continental Insurance Company ("Continental") in the state-court action. The third-party complaint alleged claims of breach of contract and bad-faith refusal to pay against National Trust and Continental. On May 4, 2023, National Trust filed a motion to dismiss in the state-court action. In the motion, National Trust asked the circuit court "to reconsider its previous Order … dated April 21, 2023, granting Whaley's motion for leave to file a third-party complaint against [National Trust] and further move[d] pursuant to Rule 12(b)(6) of the Alabama Rules of Civil Procedure to dismiss both of Whaley's claims asserted against [National Trust] in the Third-Party Complaint." In its motion, National Trust asserted that Whaley's claims against it were due to be dismissed "because they were compulsory counterclaims that Whaley was required to file in the federal[-court] action pursuant to § 65-440, Ala. Code 1975." On June 7, 2023, the circuit court entered an order denying National Trust's motion to dismiss the third-party complaint. National Trust subsequently filed a petition for a writ of mandamus asking this Court to direct the circuit court to enter an order dismissing National Trust from the state-court action.The Supreme Court of Alabama granted National Trust's mandamus petition in part and issued a writ directing the circuit court to enter an order dismissing Whaley's breach-of-contract and bad-faith claims in the state-court action that were based on National Trust's refusal to indemnify Whaley for the amount it had paid to settle Lockheed Martin's indemnity claim against it. However, the court denied the petition as to Whaley's contingent claims for a defense and indemnification. View "Ex parte National Trust Insurance Company" on Justia Law

The case involves a wrongful-death action initiated by Veronica Edwards and Corey D. Hatcher, Sr., following the death of Corey Demills Hatcher, Jr. The deceased died from injuries sustained when his vehicle collided with horses on a road. The plaintiffs sued the owners of the horses, Kimberly Johnson Crowder and Carole A. Phillipsen, as well as Southern Sportsman Hunting Lodge, Inc., its owners, and the McCurdy Plantation Horse Association, which hosted a trail ride on Southern Sportsman's property. The plaintiffs alleged that the defendants failed to use proper fencing to corral the horses, leading to the accident.The Lowndes Circuit Court entered a summary judgment in favor of the defendants. The court determined that the plaintiffs' wrongful-death claim was the exclusive remedy available under Alabama Code § 3-5-3(a), which provides a cause of action against livestock owners who knowingly or willfully place their animals on a public highway. The court found that the plaintiffs failed to produce substantial evidence to support their claim that the defendants knowingly placed the horses on the highway.On appeal, the Supreme Court of Alabama affirmed the circuit court's judgment. The court clarified that § 3-5-3(a) creates a cause of action that did not exist at common law, rather than shielding certain defendants from liability. The court found that the plaintiffs failed to present substantial evidence that the defendants knowingly placed the horses on the highway, as required by § 3-5-3(a). Therefore, the plaintiffs could not pursue any cause of action against the defendants. View "Edwards v. Crowder" on Justia Law

Harold Wallace, a tenant of the Housing Authority of the City of Talladega, fell while descending the back-porch stairs of his apartment due to missing handrails. Wallace sued the Housing Authority for negligence and wantonness. The Housing Authority moved for a summary judgment, arguing that the lack of handrails was an "open and obvious" danger and that Wallace had conceded in his deposition that he was aware of this. The trial court granted the Housing Authority's motion for a summary judgment. Wallace appealed to the Court of Civil Appeals.The Court of Civil Appeals reversed the trial court's summary judgment in favor of the Housing Authority. The Housing Authority then petitioned the Supreme Court of Alabama for certiorari review, arguing that the Court of Civil Appeals' decision conflicts with a prior decision in Daniels v. Wiley, where the court affirmed a summary judgment for the defendant landlord after concluding that the landlord had no duty to the plaintiff tenant with respect to risks created by the muddy condition of a sidewalk within her apartment complex because the danger was "open and obvious."The Supreme Court of Alabama affirmed the decision of the Court of Civil Appeals, concluding that the decision does not conflict with Daniels. The court clarified that while the Daniels decision is sound, it should not be interpreted as rejecting a landlord's duties under the circumstances described in §§ 360 and 361 of the First Restatement and the Second Restatement. The court found that the Housing Authority failed to raise a genuine issue of material fact as to whether the principles set forth in §§ 360 and 361 apply to the circumstances in this case, and therefore, the Housing Authority was not entitled to a judgment as a matter of law. View "Ex parte The Housing Authority of the City of Talladega" on Justia Law

The Supreme Court of Alabama reviewed a case involving a dispute over an undeveloped island ("the island") located within a canal system on Ono Island, a residential subdivision. The island was created during the development of the canal system and was later sold in a tax sale. F Family South, LLC ("FFS") acquired the island and sought to construct a boat shelter on it. The Property Owners Association of Ono Island, Inc. ("the POA") objected, arguing that the island was subject to certain covenants restricting its use.The Baldwin Circuit Court ruled in favor of the POA, finding that the island was subject to both express and implied covenants restricting its use. The court also invalidated the 1995 tax sale through which FFS had obtained ownership of the island, and declared the POA as the island's owner.FFS appealed, arguing that the trial court erred in voiding the 1995 tax sale and in concluding that the island was subject to the covenants. The Supreme Court of Alabama reversed the trial court's decision to void the tax sale, but affirmed the finding that the island was subject to implied restrictive covenants governing its use. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "F Family South, LLC v. Property Owners Association of Ono Island, Inc." on Justia Law