Justia Civil Procedure Opinion Summaries

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 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

In October 2020, Larry Knight's residence was damaged by Hurricane Zeta. He filed an insurance claim with Foremost Insurance Company, which was denied. Knight then sued Foremost, claiming that the company had insured his residence. Over the course of the litigation, Knight amended his complaint six times, eventually adding claims related to a rental property that Foremost admitted to insuring. He also added Karen Bradford and Bradford Agency, LLC as defendants. Foremost moved to strike Knight's latest amended complaint, while Bradford and the Agency moved to quash service of process and to be dismissed from the case, arguing that service on them had been insufficient. The trial court denied these motions.Foremost, Bradford, and the Agency petitioned the Supreme Court of Alabama for a writ of mandamus, arguing that they were entitled to relief. The court agreed, finding that Knight had failed to demonstrate good cause for amending his complaint for a sixth time and that allowing the amendment would result in actual prejudice to Foremost and unduly delay the trial. The court also found that service on Bradford and the Agency was ineffective, as Knight had failed to comply with the service requirements in Rule 4 of the Alabama Rules of Civil Procedure. The court therefore granted the petition and issued the writ, directing the trial court to strike Knight's sixth amended complaint and to grant Bradford and the Agency's motions to quash service of process and to dismiss them from the lawsuit. View "Ex parte Foremost Insurance Company v. Foremost Insurance Company" on Justia Law

The case involves Carl Michael Seibert who appealed a summary judgment by the Madison Circuit Court in favor of Lorri Stricklen and Zoe Aldige. Seibert had filed claims of malicious prosecution and abuse of process against Stricklen and Aldige. The case originated from a divorce proceeding between Seibert and Stricklen. Seibert believed Stricklen was having an affair and began gathering evidence. Stricklen filed a criminal complaint against Seibert for stalking, leading to his arrest and indictment. The criminal case ended in a mistrial, and Seibert subsequently filed his complaint alleging malicious prosecution and abuse of process.The Madison Circuit Court granted a summary judgment in favor of Stricklen and Aldige, noting that Seibert's case had effectively languished due to his failure to conduct meaningful discovery or prosecute the case. The court found that if Seibert could not defeat a motion for a summary judgment after 58 months, a trial on his claims would be useless. Stricklen and Aldige also filed a motion for an award of attorney fees and costs under the Alabama Litigation Accountability Act ("the ALAA"), which the court granted in part.The Supreme Court of Alabama affirmed in part and reversed in part. It affirmed the lower court's summary judgment in favor of Stricklen on the malicious-prosecution claim and in favor of Stricklen and Aldige on the abuse-of-process claim. However, it reversed the trial court's implicit determination that Seibert's lawsuit was filed without substantial justification, remanding the case to the trial court with instructions to set forth its reasoning as to why Stricklen and Aldige are entitled to an award of attorney fees and costs under the ALAA. View "Seibert v. Stricklen" on Justia Law

The State of Alabama initiated 14 separate actions against various businesses, nonprofit organizations, property owners, and municipalities, alleging that they were responsible for the operation of illegal gambling activities. The State sought permanent injunctive relief on public-nuisance grounds. The Birmingham Division of the Jefferson Circuit Court issued temporary restraining orders (TROs) in each case and later transferred the actions to the Bessemer Division of the same court, extending the TROs in the process.Upon receiving the transferred cases, the Bessemer Division concluded that the Birmingham Division lacked jurisdiction to issue the TROs. As a result, the Bessemer Division dissolved the TROs and dismissed the actions. The State appealed these decisions, leading to the consolidation of the appeals.The Supreme Court of Alabama found that the Bessemer Division had erred in its conclusion. The court clarified that the Birmingham Division did have jurisdiction over the actions and had correctly transferred them to the Bessemer Division, which was the proper venue. The court explained that the Bessemer Division's dismissal of the actions was erroneous and that the correct course of action would have been to proceed with the cases.The Supreme Court of Alabama reversed the Bessemer Division's judgments and remanded the actions for further proceedings. The court instructed the Bessemer Division to conduct a hearing regarding the State's motions for preliminary injunctions at the earliest possible time. View "State of Alabama v. Jay's Charity Bingo" on Justia Law

This case involves a dispute over church property between Harvest Church-Dothan ("Harvest") and the Alabama-West Florida Conference of the United Methodist Church, Inc. ("the AWFC") and the General Council on Finance and Administration of the United Methodist Church ("the GCFA"). Harvest sought a judgment declaring that the AWFC and the GCFA lack any legally cognizable interest in real or personal property held by Harvest, as well as injunctive relief preventing the AWFC and the GCFA from interfering with Harvest's use, ownership, or control of the local church property.The AWFC and the GCFA moved to dismiss the action, arguing that the trial court lacked subject-matter jurisdiction based on the ecclesiastical abstention doctrine, which prohibits civil courts from adjudicating disputes concerning spiritual or ecclesiastical matters. The trial court denied the motion to dismiss. The AWFC and the GCFA then petitioned the Supreme Court of Alabama for a writ of mandamus directing the trial court to dismiss the underlying action.The Supreme Court of Alabama denied the petition, concluding that the AWFC and the GCFA have not met their burden of demonstrating a clear legal right to have the complaint against them dismissed. The court found that the dispute pertains solely to the ownership and control of the local church property, an issue that civil courts generally can resolve by applying "neutral principles of law." The court also found that the AWFC and the GCFA failed to demonstrate that the trial court's exercise of personal jurisdiction over the GCFA was improper. The action will continue in the trial court for further proceedings. View "Ex parte The Alabama-West Florida Conference of the United Methodist Church, Inc." on Justia Law

The case involves Alabama Relocation Services, Inc. ("ARS") and Patricia Buchannan, who filed a complaint against COWS USA, LLC ("COWS"), Trailpods Acceptance Corporation ("Trailpods"), Michael Frank, Ana Frank, and Leonard Rosenberg ("the COWS defendants"). ARS is a moving and storage company based in Mobile, Alabama, and Buchannan is its vice president. COWS is a Florida-based company that sells portable storage containers. ARS and Buchannan allege that they entered into a dealership agreement with COWS, which required them to lease equipment from Trailpods and finance the purchase of COWS equipment through Ascentium Capital, LLC ("Ascentium"). However, they claim that despite making payments, the promised equipment was never delivered.The COWS defendants filed a motion to dismiss the claims, arguing that the dealership agreement contained a forum-selection clause requiring disputes to be brought in Miami-Dade County, Florida. The Mobile Circuit Court denied their motion to dismiss. The COWS defendants then petitioned the Supreme Court of Alabama for a writ of mandamus, seeking an order directing the Mobile Circuit Court to vacate its order denying their motion to dismiss and to enter an order dismissing the claims.The Supreme Court of Alabama granted the petition. The court found that the dealership agreement's forum-selection clause clearly required actions between the parties to be brought in Miami, Florida. The court concluded that ARS and Buchannan failed to clearly establish that enforcement of the forum-selection clause would be unreasonable. The court directed the Mobile Circuit Court to vacate its order denying the COWS defendants' motions to dismiss and to enter a new order dismissing the claims against the COWS defendants, without prejudice. View "Ex parte Cows USA, LLC" on Justia Law

The case revolves around a car accident that occurred on February 6, 2016, involving Melissa A. Keller and her daughter, Caroline Keller, who were insured by State Farm Mutual Automobile Insurance Company. The Kellers were hit by Xavier Blanchard, who ran a red light. Xavier's vehicle was owned by his father, Harvey Blanchard, and was also insured by State Farm. The Kellers filed a complaint against the Blanchards on January 8, 2018, alleging negligence and wantonness. However, the complaint did not state any claim against State Farm. On January 26, 2023, the Kellers settled their claims with the Blanchards and subsequently filed an "Amended Complaint for Underinsured Motorist Coverage" against State Farm on January 27, 2023.State Farm moved to dismiss the new complaint, arguing that it was filed outside the six-year statute-of-limitations period applicable to contract-based claims. The insurer contended that the claim did not relate back to the original complaint as Keller knew or should have known that State Farm was her insurer. Keller, on the other hand, argued that her claim for underinsured-motorist coverage did not accrue until the date she settled with the Blanchards. The trial court denied State Farm's motion to dismiss on June 12, 2023, without making specific findings of fact or law.The Supreme Court of Alabama granted State Farm's petition for a writ of mandamus, directing the trial court to dismiss Keller's underinsured-motorist claim against it. The court held that the accrual date for a direct uninsured/underinsured-motorist claim against an insurer is the date of the accident. Since Keller did not assert her direct claim for underinsured-motorist benefits against State Farm until more than six years after the date of the accident, that claim was time-barred. View "Ex parte State Farm Mutual Automobile Insurance Company" on Justia Law