Justia Constitutional Law Opinion Summaries

Luther Pate, IV sought review of the Court of Criminal Appeals' decision to affirm his conviction for menacing. In a matter of first impression, the issues before the Supreme Court were: (1) whether lawfully arming oneself was a "physical action" as defined in the state menacing statute; and (2) whether defense-of-premises was applicable in this case. Finding that the Court of Criminal Appeals erred in its analysis of the menacing statute, the Supreme Court reversed and remanded the case for further proceedings. The Court held that its reversal on the menacing issue pretermitted discussion of the defense-of-premises issue. View "Pate IV v. City of Tuscaloosa" on Justia Law

Defendants U.S. Innovations Group, Inc. (and several others) petitioned the Supreme Court for a writ of mandamus to order the trial court to dismiss claims filed against it by Judy Hawke and Carolyn Grimes. Defendants argued that because the claims arose on a federal enclave subject to exclusive federal jurisdiction, the trial court lacked jurisdiction to hear the claims. Finding that defendant did not demonstrate the trial court lacked jurisdiction or that they had a clear right to have those claims dismissed, the Supreme Court denied their petitions for the writ. View "Hawke v. U.S. Centrifuge Systems, LLC" on Justia Law

USA Water Ski, Inc. sought a writ of mandamus to direct the trial court to vacate its discovery order compelling the production of a report that it deemed privileged under the work-product doctrine. Finding that USA Water Ski adequately explained that it's hired expert's post-incident report was prepared because of prospective litigation, the Supreme Court found USA Water Ski had shown the trial court exceeded its discretion in ordering production of the report. Accordingly the Court granted the petition and issued the writ. View "Ewing v. USA Water Ski, Inc." on Justia Law

Petitioner Tonya Cate sought a writ of mandamus to direct the trial court to vacate its order requiring her to submit for a mental examination. She was indicted for capital murder and did not use the not-guilty-by-reason-of-mental-defect defense. At the onset, a mitigation expert was concerned Petitioner had not been subjected to the exam to determine her competency to stand trial. Petitioner's attorney filed a motion for a continuance for his client to be examined, but did not specify that the exam was only to determine competence. The State filed a motion to have Petitioner examined for both current mental condition and competency to stand trial. Petitioner claims to have not been served with a copy of the trial court's order that granted the State's motion, and objected. In her motion to avoid the exam, Petitioner asked in the alternative that if the exam took place, her attorney be present to advise her of her constitutional rights. Before the court ruled on the motion, Petitioner withdrew her original motion, citing the mitigation expert's concerns had been allayed. The court entered its order requiring Petitioner to submit to the examination for then-current mental state and at the time of the alleged crime. Petitioner argued that after withdrawing her own motion for an examination, she could not be compelled to submit for examination. Because Petitioner did not use the mental-defect defense, the Supreme Court concluded that she could not be compelled to submit to the examination. Accordingly the Court granted the petition and issued the writ. View "Cate v. Alabama " on Justia Law

Plaintiff SafetyNet Youth Systems, LLC sued Defendants Guarantee Insurance Company, Patriot National Insurance Group, Randy Thomas, and Paul Harper in Dallas County Circuit Court. Defendants sought the writ of mandamus to direct the Dallas court to grant their motion for a transfer of venue to Lee County. Upon review, the Supreme Court concluded Dallas County was an inappropriate forum, and granted defendant's petition and issued the writ. View "Safetynet Youth Systems, LLC v. Guarantee Insurance Co." on Justia Law

Tyson Foods, Inc. petitioned the Supreme Court for a writ of mandamus to direct the Blount Circuit Court to dismiss Reba Kirkley's action against it, brought in her capacity as administratrix of her father's estate, on the ground that Kirkley lacked standing. On April 15, 2008, Allen Hayes died in a workplace accident at the Tyson Foods plant in Blount County. A tractor operated by an employee of Tyson Foods hit Hayes, who was working as a security guard. His widow Mildred Hayes collected $40,964.19 in workers' compensation death benefits against the account of DSI Security Services, Allen's employer at the time of the accident. On June 26, 2008, Kirkley, the personal representative of Allen's estate and Allen and Mildred's daughter, filed a wrongful-death action against the Tyson petitioners, who answered and removed the case to federal court. In early March 2011, the federal court remanded the case to state court. The trial judge denied the motion to dismiss. Finding that Tyson did not demonstrate a clear legal right to the remedy it sought seek, the Supreme Court denied the petition. View "Kirkley v. Tyson Foods, Inc." on Justia Law

Defendants Marathon Construction and Demolition, LLC, and OAX, LLC, appealed a circuit court order granting injunctive relief to the plaintiff King Metal Recycling and Processing Corporation. King Metal sued Marathon and OAX, alleging breach of contract, breach of the implied covenant of good faith and fair dealing, unjust enrichment, interference with contractual relations, and breach of fiduciary duty/duty of loyalty. King Metal alleged that it had entered into an agreement with Marathon to purchase, demolish, and redevelop the former Delphi Industrial Complex in Limestone County ("the Delphi Project"). King Metal also alleged that OAX was formed by it and Marathon as the entity through which they would complete the Delphi Project. King Metal alleged that it filed the complaint after becoming concerned that it was being "frozen out" of the Delphi Project. It also filed a motion for a preliminary injunction. The trial court entered an order for a writ of seizure in which it ordered that the net proceeds of the Delphi Project be seized. Defendants filed a motion to quash the order for a writ of seizure, arguing, in part, that the writ was the incorrect procedure for the remedy sought and asserting that King Metal should have instead requested a temporary restraining order. King Metal filed a motion in opposition to the defendants' motion to quash the order for a writ of seizure, and after a hearing, the writ of seizure was set aside, and a temporary restraining order issued instead. The Supreme Court reversed the trial court's decision to enjoin sale portion of the Delphi site because it did not conform with the Alabama Rules of Civil Procedure. "This decision should not be interpreted as precluding King Metal, should it deem it necessary, from asking the trial court to again issue a preliminary injunction, provided that any such injunction complies with Rule 65, Ala. R. Civ. P." View "Marathon Construction & Demolition, LLC v. King Metal Recycling & Processing Corp. " on Justia Law

Transportation Leasing Corp. ("TLC") and Aquilex Hydrochem, LLC, petitioned the Supreme Court for a writ of mandamus to order the Perry Circuit Court to vacate its order denying TLC and Aquilex's motion to dismiss the action without prejudice to refile in Mississippi in accordance with the doctrine of forum non conveniens and to enter an order dismissing the action without prejudice. Ronald Weir, a resident of Mississippi, was severely injured in an automobile accident in Meridian, Mississippi. Weir filed a complaint in the Perry Circuit Court naming as defendants TLC, Aquilex, Floyd Hershey, and Gordon Booker and alleging negligence, wantonness, and negligent entrustment. In his complaint, Weir alleged that TLC was a corporate entity whose principal office is located in Illinois and that Booker, an Alabama resident, was operating a vehicle owned by TLC when the accident occurred. Weir alleged that Aquilex was a corporate entity whose principal office is located in Ohio and that Hershey, a resident of Ohio, was operating a vehicle owned by Aquilex when the accident occurred. Weir sued TLC, Aquilex, Booker, and Hershey. The petitioners argued that Mississippi was a more convenient forum because Booker was the only connection the action had to Alabama and the majority of witnesses and accident-related documents were in Mississippi. Upon review, the Supreme Court held that the circuit court exceeded its discretion in denying petitioners' motion for a dismissal based on the doctrine of forum non conveniens. The Court granted their petition and issued the writ. View "Ex parte Transportation Leasing Corp., and Aquilex Hydrochem, LLC" on Justia Law

Brooks Insurance Agency, Sidney Brooks (its agent), and Nationwide Mutual Insurance Company and Nationwide Mutual Fire Insurance Company (collectively "Nationwide") petitioned the Supreme Court for a writ of mandamus to direct the Jefferson Circuit Court to vacate its order denying their motion to dismiss an action filed by Guster Law Firm, LLC, and Guster Properties, LLP (collectively "Guster"), against them. Guster made a claim for a fire loss under commercial property policies issued to it by Nationwide. In April 2011, Nationwide filed a declaratory-judgment action requesting that the federal court determine the rights and obligations under the insurance policies it had issued to Guster. Guster answered and asserted compulsory counterclaims against Nationwide, including bad-faith failure to pay an insurance claim and breach of contract, among others. Months later, Guster filed a lawsuit in the Jefferson Circuit Court alleging against the agency, Brooks, and Nationwide: negligent/wanton failure to provide insurance coverage; misrepresentation; suppression and concealment; and negligent/wanton failure to train. The agency, Brooks, and Nationwide moved to dismiss the state court action on the ground that the action violated the state abatement statute and the compulsory-counterclaim rule. The trial court summarily denied the motion to dismiss. The agency, Brooks, and Nationwide then petitioned the Supreme Court for mandamus relief. Upon review, the Supreme Court affirmed in part, reversed in part, and issued the writ. Although the causes of action in the federal court and the state court arose out of the same transaction or occurrence and were thus related, Guster's claims against the agency and Brooks were not compulsory counterclaims in the federal declaratory-judgment action because the agency and Brooks were not "opposing part[ies]" in the federal action. Accordingly, the Alabama abatement statute mandated that the claims against Nationwide in Guster's complaint filed in state court be dismissed. The Court concluded that the agency and Brooks did not show a clear legal right to the dismissal of Guster's claims against them in the state-court action. However, Nationwide did show a clear legal right to the dismissal of Guster's claims against it in the state-court action, therefore the trial court erred in denying the motion to dismiss as to Nationwide. View "Guster Law Firm, LLC v. Brooks Insurance Agency" on Justia Law

Roosevelt Upshaw appealed a circuit court's decision to deny his petition for habeas relief. In his petition, Upshaw alleged that the Alabama Department of Corrections ("ADOC") had erred in calculating the term of his sentence after he was arrested while on parole in that ADOC unlawfully denied him credit under 15-22-32(a), Ala. Code 1975, for the time he was incarcerated in Georgia. Finding no error, the Supreme Court affirmed. View "Upshaw v. Alabama" on Justia Law