Justia Alabama Supreme Court Opinion Summaries

In January 2019, Raymond Robinson and his son sued Emerald Homes, L.L.C., and 21st Mortgage Corporation in the Baldwin Circuit Court. Robinson had contracted with Emerald to purchase a mobile home, financed by a loan from 21st Mortgage. After tearing down his existing house in preparation for the new mobile home, the loan was not completed, allegedly due to Emerald and/or 21st Mortgage's refusal to finalize the transaction. The complaint included claims of breach of contract, misrepresentation, suppression, and negligence, seeking compensatory and punitive damages.The trial court compelled arbitration for claims against Emerald and granted summary judgment in favor of 21st Mortgage on Raymond's claims. The case proceeded to a jury trial on Robinson's claims against 21st Mortgage. The jury found in favor of Robinson on promissory fraud and the tort of outrage, awarding him $2,980,000 in total damages. 21st Mortgage's post-trial motions, including for judgment as a matter of law (JML), were denied.The Supreme Court of Alabama reviewed the case. It held that Robinson did not present substantial evidence of promissory fraud, as he failed to prove that 21st Mortgage had no intention to perform the loan promise at the time it was made or intended to deceive him. The court also found that Robinson did not meet all the conditions required for the loan, and the failure to close the loan was not due to any fraudulent intent by 21st Mortgage.Regarding the tort of outrage, the court held that the conduct of 21st Mortgage did not meet the extreme and outrageous standard required for such a claim. The court reversed the trial court's judgment and remanded the case for further proceedings consistent with its opinion. View "21st Mortgage Corporation v. Robinson" on Justia Law

In January 2023, the Keenums and Karibu Home Builders, LLC entered into a real-estate sales contract where the Keenums agreed to sell seven lots and construct a paved road before the closing date. The contract included dispute-resolution provisions for mediation and arbitration. The Keenums did not complete the road or appear for the closing. Karibu sued for specific performance and damages, claiming the Keenums breached the contract. The Keenums argued the contract was void due to Karibu's failure to meet obligations and the requirement for mediation and arbitration.The Colbert Circuit Court granted summary judgment in favor of the Keenums, dismissing the case with prejudice. The court concluded it lacked subject-matter jurisdiction due to the contract's mediation and arbitration provision, implying Karibu should have filed directly with the American Arbitration Association.The Supreme Court of Alabama reviewed the case de novo and found that the trial court erred in concluding it lacked jurisdiction. The court held that the trial court had the authority to determine whether the mediation and arbitration provision applied and should have compelled arbitration rather than dismissing the case. The summary judgment was reversed, and the case was remanded for further proceedings consistent with the opinion. View "Karibu Home Builders, LLC v. Keenum" on Justia Law

Carl Grant, a Vietnam War veteran suffering from dementia and PTSD, left his home in Conyers, Georgia, on February 2, 2020, and ended up in Birmingham, Alabama. Officer Vincent Larry of the Birmingham Police Department found Grant disoriented and detained him for a misdemeanor. Grant was taken to a hospital, where he was treated for minor injuries. While being escorted to the restroom, Larry allegedly assaulted Grant, causing severe spinal injuries that led to Grant's death on July 24, 2020. William Jenkins, representing Grant's estate, filed a lawsuit against Larry, the City of Birmingham, and various city officials.The Jefferson Circuit Court granted a summary judgment in favor of the City defendants, dismissing Jenkins's claims with prejudice on February 22, 2023. Jenkins filed a postjudgment motion on March 21, 2023, which was denied by operation of law on June 20, 2023. Jenkins also filed a "motion for clarification" on April 28, 2023, which the court purported to grant on June 21, 2023, reinstating claims against Larry and Scott Thurmond. However, this order was a nullity as the court had lost jurisdiction after the postjudgment motion was denied by operation of law.Jenkins filed a notice of appeal on November 3, 2023, which was dismissed as arising from a non-final order. He then filed another appeal on January 24, 2024, which was transferred to the Supreme Court of Alabama. The Supreme Court of Alabama dismissed the appeal, instructing the circuit court to vacate its June 21, 2023, order and all subsequent orders, as they were nullities. The February 22, 2023, judgment was deemed final, and Jenkins's failure to appeal it timely resulted in the dismissal of his current appeal. View "Jenkins v. City of Birmingham" on Justia Law

The Caribe Resort Condominium Association Board of Directors, Larry Wireman, and Judy Wireman, along with Caribe Realty, Inc., Caribe, Inc., and Sentinels, LLC, sought a writ of mandamus to direct the Baldwin Circuit Court to dismiss derivative claims brought by Robert Simmons and other condominium-unit owners on behalf of the Caribe Resort Condominium Association. The claims included allegations of breaching duties, wasting corporate assets, entering into inflated self-dealing contracts, and misappropriating funds.The Baldwin Circuit Court denied the motion to dismiss, leading to the current petition. The petitioners argued that Alabama law does not recognize derivative actions on behalf of nonprofit corporations. They noted that while Alabama law allows derivative actions for for-profit corporations, limited-liability companies, and limited partnerships, it does not provide similar provisions for nonprofit corporations. They also pointed out that the Alabama Nonprofit Corporation Law, which adopted the Model Nonprofit Corporation Act, intentionally omitted the chapter on derivative proceedings.The Supreme Court of Alabama agreed that Alabama law does not generally recognize derivative actions for nonprofit corporations. However, it noted that under § 10A-3-2.44(2), Ala. Code 1975, members of a nonprofit corporation can bring a representative suit against officers or directors for exceeding their authority. The court found that the Caribe members' claims against the board defendants alleged that the board exceeded their authority, thus falling under this provision. However, claims against the Wireman companies did not fall under this provision and were due to be dismissed.The Supreme Court of Alabama granted the petition in part, dismissing the claims against the Wireman companies, and denied it in part, allowing the claims against the board defendants to proceed. View "Ex parte Caribe Resort Condominium Association Board of Directors" on Justia Law

Joshua Lashawn Booth was convicted in 2018 of three counts of possession of obscene material and sentenced to 15 years in prison. While incarcerated, Booth filed an application for a writ of habeas corpus in the Bibb Circuit Court, claiming that the Alabama Department of Corrections (ADOC) refused to grant him correctional incentive time. Booth argued that the statute barring sex offenders from receiving such time did not apply to his convictions. ADOC moved to dismiss or for summary judgment, but the Bibb Circuit Court denied the motion and ruled in favor of Booth, ordering ADOC to calculate his correctional incentive time.ADOC appealed to the Court of Criminal Appeals, arguing that Booth's filing should have been a petition for a writ of certiorari in the Montgomery Circuit Court, not a habeas corpus application in the Bibb Circuit Court. The Court of Criminal Appeals agreed, reversed the Bibb Circuit Court's judgment, and directed the case to be transferred to the Montgomery Circuit Court.The Supreme Court of Alabama reviewed the case to determine if the Court of Criminal Appeals' decision conflicted with Ex parte Culbreth and Ex parte Tanksley. The Supreme Court concluded that the issue was one of venue, not jurisdiction, and that ADOC had waived its objection to improper venue by not raising it in the Bibb Circuit Court. The Supreme Court found that the Court of Criminal Appeals' decision was in conflict with the precedent that venue objections can be waived if not timely raised. Consequently, the Supreme Court reversed the Court of Criminal Appeals' decision and remanded the case for proceedings consistent with its opinion. View "In re Alabama Department of Corrections v. Booth" on Justia Law

A minor, Iyana Crenshaw, was injured while working at Sonic Drive In of Greenville, Inc. Her father, Derrick Crenshaw, filed a negligence lawsuit against Sonic, alleging that the injury was caused by Sonic's negligence. The complaint did not seek workers' compensation benefits but solely pursued a negligence claim.The Butler Circuit Court dismissed the negligence action, concluding that the exclusive-remedy provisions of the Alabama Workers' Compensation Act barred the claim. Crenshaw did not dispute that Iyana's injury was subject to the Act but argued that the Act itself was unconstitutional under Article I, § 13, of the Alabama Constitution of 2022. The attorney general and Sonic defended the constitutionality of the Act, and the circuit court rejected Crenshaw's constitutional challenges, leading to the dismissal of the negligence action.The Supreme Court of Alabama reviewed the case and affirmed the lower court's decision. The court held that the Alabama Workers' Compensation Act does not violate Article I, § 13, of the Alabama Constitution. The court applied both the vested-rights approach and the common-law-rights approach to determine the constitutionality of the Act. Under the vested-rights approach, the Act did not deprive Crenshaw of a vested right in a cause of action. Under the common-law-rights approach, the court concluded that the Act was a valid exercise of the legislature's police power, as it eradicated or ameliorated a perceived social evil. Therefore, the Act's exclusive-remedy provisions were upheld, and the dismissal of the negligence action was affirmed. View "Crenshaw v. Sonic Drive In of Greenville, Inc." on Justia Law

In May 2022, Jerry & John Woods Construction, Inc. ("Woods Construction") entered into a contract with John David Jordan and Carol S. Jordan to construct a house and a metal building. Woods Construction claimed the Jordans failed to pay for the work performed, leading the company to sue them in the Dallas Circuit Court for breach of contract and unjust enrichment. The Jordans moved to dismiss or for summary judgment, arguing that Woods Construction's lack of a required residential-home-builder's license barred the company from bringing civil claims. They also filed counterclaims alleging improper and negligent work by Woods Construction.The Dallas Circuit Court denied the Jordans' motion to dismiss but later granted their motion for summary judgment, finding that Woods Construction, as an unlicensed residential home builder, was barred from enforcing the construction contract under § 34-14A-14(d) of the Alabama Code. The court also declared Woods Construction's "Notice of Lis Pendens/Lien" null and void. The court certified its judgment as final under Rule 54(b), despite the Jordans' counterclaims remaining pending.The Supreme Court of Alabama reviewed the case and determined that the Rule 54(b) certification was improper. The court noted that the claims and counterclaims were closely intertwined, as both concerned the same contract and construction work. Additionally, the resolution of the Jordans' counterclaims could potentially moot Woods Construction's claims. Therefore, the court concluded that the circuit court exceeded its discretion in certifying the judgment as final and dismissed the appeal for lack of a final judgment. View "Jerry & John Woods Construction, Inc. v. Jordan" on Justia Law

Gary Everett Martin obtained a home-equity line of credit (HELOC) from BBVA USA Bancshares, Inc. (BBVA) in May 2008, secured by a mortgage on his residential property. In June 2008, Martin hired Joseph T. Scarborough, Jr., and Scarborough & Griggs, LLC (S&G) for legal representation in a divorce action. In June 2012, Martin executed a promissory note in favor of S&G for legal fees, secured by a second mortgage on the property. The attorney-client relationship ended in June 2013, and the promissory note and mortgage were later assigned to Scarborough. In June 2019, BBVA foreclosed on the property, and Scarborough purchased it at the foreclosure sale.The Lee Circuit Court granted summary judgment in favor of Scarborough, S&G, and BBVA, dismissing Martin's counterclaims and awarding possession of the property to Scarborough. The court found Martin's claims against the Scarborough parties time-barred under the Alabama Legal Services Liability Act (ALSLA) and dismissed his claims against BBVA as time-barred or unsupported by substantial evidence.The Supreme Court of Alabama reviewed the case. It found a genuine issue of material fact regarding the validity of the foreclosure sale, as the sale price was significantly lower than the property's fair market value, potentially indicating fraud or unfairness. Consequently, the court reversed the summary judgment in favor of Scarborough on his ejectment claim and remanded the case for further proceedings. However, the court affirmed the summary judgment in favor of the Scarborough parties and BBVA regarding Martin's counterclaims, finding them time-barred or unsupported by substantial evidence. View "Martin v. Scarborough" on Justia Law

Hudgen LeBlanc and Jodi LeBlanc filed a complaint against Residence Doctor Home Inspection, LLC, and its owner-operator, Terry J. Holder, alleging negligence, wantonness, gross negligence, fraudulent/innocent misrepresentation, suppression, and breach of contract. The claims arose from a pre-purchase home inspection performed by Holder, which the LeBlancs claimed failed to report structural issues with the flooring of the home they purchased. Instead, the report only mentioned "microbial growth" on the floor joists and recommended hiring a mold-remediation specialist. After purchasing the home, the LeBlancs hired a mold-remediation specialist who discovered rotten floor joists, costing nearly $40,000 to repair.The St. Clair Circuit Court granted summary judgment in favor of the inspection company and Holder on the negligence and breach-of-contract claims and dismissed the fraud, suppression, and wantonness claims with prejudice. The court found that the LeBlancs failed to provide expert testimony to establish the applicable standard of care or Holder's breach of that standard, which was necessary to prove their claims.The Supreme Court of Alabama reviewed the case de novo. The court held that expert testimony is required to establish a home inspector's breach of the applicable standard of care, similar to other professionals such as real-estate appraisers, engineers, and architects. The LeBlancs did not present expert testimony or establish that the breach was so obvious that it did not require expert testimony. Consequently, the Supreme Court of Alabama affirmed the trial court's summary judgment in favor of the inspection company and Holder. View "LeBlanc v. Residence Doctor Home Inspection, LLC" on Justia Law

Shymikka Griggs filed a data-breach action against NHS Management, LLC, a consulting firm providing management services for nursing homes and physical-rehabilitation facilities. NHS collects sensitive personal and health information from employees, patients, and vendors. In May 2021, NHS discovered a cyberattack on its network, which lasted 80 days. NHS notified affected individuals, including Griggs, in March 2022. Griggs, a former NHS employee, claimed her personal information was found on the dark web, leading to credit issues, spam communications, and fraudulent activities.Griggs initially filed a class-action complaint in the United States District Court for the Northern District of Alabama but later dismissed it. She then filed a class-action complaint in the Jefferson Circuit Court in June 2023, alleging negligence, negligence per se, breach of contract, invasion of privacy, unjust enrichment, breach of confidence, breach of fiduciary duty, and violation of the Alabama Deceptive Trade Practices Act. NHS moved to dismiss the complaint, arguing lack of standing and failure to state a claim. The Jefferson Circuit Court dismissed Griggs's complaint with prejudice.The Supreme Court of Alabama reviewed the case and affirmed the circuit court's judgment. The court held that Griggs failed to sufficiently plead her claims. Specifically, she did not demonstrate that NHS owed her a duty under Alabama law, failed to establish proximate cause for her negligence per se claim, did not allege intentional conduct for her invasion-of-privacy claim, and did not show that she conferred a benefit on NHS for her unjust-enrichment claim. Additionally, the court found that breach of confidence is not a recognized cause of action in Alabama and that Griggs did not establish a fiduciary relationship between her and NHS. View "Griggs v. NHS Management, LLC" on Justia Law