Justia Constitutional Law Opinion Summaries

Articles Posted in Supreme Court of Alabama
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David Bronner, secretary-treasurer of the Public Education Employees' Health Insurance Plan ("PEEHIP"), and individual members of the Board of Control of PEEHIP ("the PEEHIP Board"), the remaining defendants in this action (collectively, "defendants"), appealed the grant of summary judgment entered in favor of the plaintiffs and members of a purported class, who were all active public-education employees and PEEHIP participants married to other active public-education employees and PEEHIP participants and who had dependent children. Before October 1, 2010, all public-education employees participating in PEEHIP earned a monthly "allocation" or benefit, which could be used to obtain certain coverage alternatives under PEEHIP. In May 2010, the PEEHIP Board voted to eliminate "the combining allocation program" and to phase in a new premium rate structure ("the 2010 policy"), which required a public-education employee married to another public-education employee to gradually begin paying the same monthly premiums for family hospital-medical coverage that other PEEHIP participants were required to pay. In May 2014, the original named plaintiffs, individually and on behalf of a class of similarly situated individuals, filed a purported class action against the defendants, among others, pursuant to 42 U.S.C. 1983. In their complaint, the original named plaintiffs sought a judgment declaring that the 2010 policy was unconstitutional under the Due Process Clause and the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution because, they claimed, the 2010 policy denied them and the members of the purported class a benefit for the payment of insurance accorded every other PEEHIP participant. The original named plaintiffs sought an order enjoining the defendants from denying them and the members of the purported class the use of that benefit, which, they claimed, would permit them and the members of the purported class to obtain family coverage at no cost. The defendants thereafter moved for a summary judgment, which the trial court denied. The Alabama Supreme Court reversed, finding nothing to indicate that the defendants intended to single out the public-education plaintiffs for disparate treatment under the 2010 policy. Accordingly, the Court concluded the 2010 policy was neither arbitrary nor discriminatory and that it did not violate either the Equal Protection Clause or the Due Process Clause of the Fourteenth Amendment to the United States Constitution. View "Bronner, et al. v. Barlow et al." on Justia Law

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Sherman Collins petitioned the Alabama Supreme Court for certiorari review of the Court of Criminal Appeals' judgment affirming Collins's convictions for capital murder for the intentional killing of Detrick Bell for pecuniary gain, and for criminal conspiracy. The appellate court also affirmed his resulting sentences of death for his capital-murder conviction and of 120 months' imprisonment for his criminal-conspiracy conviction. The Supreme Court granted review to consider whether the Court of Criminal Appeals' decision was in conflict with Blockburger v. United States, 284 U.S. 299 (1932); the Alabama Court concluded that it was. As a result, the Supreme Court affirmed the Court of Criminal Appeals' decision insofar as it affirmed Collins's capital-murder conviction and his resulting death sentence, but reversed the decision insofar as it affirmed Collins's criminal-conspiracy conviction and his resulting sentence to 120 months' imprisonment. The case was remanded to the Court of Criminal Appeals to remand the cause to the trial court to set aside Collins's criminal-conspiracy conviction and resulting sentence. View "Ex parte Sherman Collins" on Justia Law

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Tom Young, Jr., a former circuit judge for the Fifth Judicial Circuit; Ray Martin, a circuit judge for the Fifth Judicial Circuit; Chris May, the Randolph Circuit Clerk; and Marlene Lindley, a former employee in May's office, petitioned the Alabama Supreme Court for a writ of mandamus directing the trial court to dismiss a complaint filed by Danny Foster, an inmate at the Ventress Correctional Facility, on grounds that they were immune from suit, that Foster lacked standing to sue, and that Foster's claims were precluded by the applicable statute of limitations. The Alabama Supreme Court found May and Lindley make no argument that, based on the face of Foster's complaint, they had a clear legal right to a summary judgment on the ground that the applicable statute of limitations barred Foster's claim against them. Moreover, Foster's complaint was devoid of any information from which the Supreme Court could determine that his claim against May and Lindley was untimely. He did not provide the dates on which he submitted his records requests. May and Lindley, therefore, "have not demonstrated that this case falls within the exception recognized in Hodge to the general rule against review by mandamus of the applicability of a statute-of-limitations defense." The Supreme Court granted the defendants' petition insofar as it sought a writ of mandamus directing the trial court to enter a summary judgment in favor of Judge Young and Judge Martin on grounds that all the claims asserted against them by Foster were barred by the doctrine of judicial immunity. The Court denied the petition, however, insofar as it sought a writ of mandamus instructing the trial court to enter a summary judgment in favor of May and Lindley regarding Foster's claim against them under the Open Records Act. View "Ex parte Young, Jr.; Martin; Lindley; and May." on Justia Law

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Johnny Lee Self petitioned the Alabama Supreme Court for review of a Court of Criminal Appeals' decision to affirm the summary dismissal of his petition for postconviction relief. In September 2003, Self pleaded guilty to two counts of first-degree sexual abuse, and was sentenced to 25 years' imprisonment; the crime of sexual abuse in the first degree was a Class C felony. Self did not appeal. In 2019, Self petitioned to challenge his convictions and sentences, arguing he had been improperly sentenced to serve 25 years in prison because the maximum sentence authorized for a Class C felony was 10 years, and, Self asserted, he "was not sentenced as a [h]abitual [o]ffender." Self also alleged "that nothing in the record shows that his sentence was properly enhanced." In 2020, the State responded, arguing Self's claim was not a jurisdictional claim, and was barred by the limitations period set forth in Rule 32.2(c), Ala. R. Crim. P. The circuit court summarily dismissed Self's Rule 32 petition, interpreting Self's claims in his Rule 32 petition as (1) a claim "that the State failed to adequately prove [Self's] prior felony convictions that were used to enhance his sentence" and (2) a claim "that the record does not reflect application of the Habitual Felony Offender Act." The Supreme Court granted certiorari review to consider whether the Court of Criminal Appeals' decision was in conflict with Barnes v. State, 708 So. 2d 217 (Ala. Crim. App. 1997), the facts of which were similar to those presented in this case. After review, the Supreme Court concluded the Court of Criminal Appeals' decision was in conflict with Barnes, thus reversing the Court of Criminal Appeals' judgment. View "Ex parte Johnny Lee Self" on Justia Law

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Amy Williamson petitioned the Alabama Supreme Court for a writ of mandamus directing the Tuscaloosa Circuit Court to enter a summary judgment in her favor based on State-agent immunity. Twenty-year-old Re.W. was a student in the CrossingPoints program, a collaborative program between the University of Alabama, the Tuscaloosa City Board of Education, and the Tuscaloosa County Board of Education that served college-aged students with mental disabilities. Williamson was a teacher in the program and an employee of the Tuscaloosa City Board of Education, and Amy Burnett was a "para-educator" with the program. In 2015, Williamson and Burnett transported Re.W. and three other students to various businesses to submit job applications. While Williamson and Burnett took two students into a Lowe's home-improvement store to submit applications, Re.W. and a male student stayed in the CrossingPoints van. Re.W. stated that, during the short time that the others were inside the store, the male student touched her on her breast and between her legs. In 2019, Re.W., by and through her parents and next friends, Ro.W. and V.W., sued Williamson on counts of negligent, wanton, and/or willful failure to perform ministerial acts and the tort of outrage. Williamson filed an answer to the complaint denying the material allegations and asserted multiple affirmative defenses. Williamson later moved for summary judgment, asserting, among other things, that Re.W.'s claims were barred by the doctrine of State-agent immunity. Because the Alabama Supreme Court concluded that Williamson established that, at the time of the incident, she was performing a discretionary function, and because the Court concluded Re.W. did not present any evidence to establish that an exception to State-agent immunity applied, Williamson established that she was entitled to State-agent immunity. Accordingly, the petition for the writ of mandamus was granted and the trial court directed to vacate its order denying Williamson's motion for a summary judgment, and directed to enter a summary judgment for Williamson. View "Ex parte Amy Williamson." on Justia Law

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Clay County Animal Shelter, Inc. ("the animal shelter"), appealed a circuit court judgment declaring Act No. 2018-432, Ala. Acts 2018, to be unconstitutional. The animal shelter was a nonprofit “no-kill” organization that provided food, water, medical care, spay and neutering services, and adoption services for stray and abandoned animals in Clay County, Alabama. Most of the people working at the animal shelter were unpaid volunteers. The animal shelter incurs numerous expenses associated with operating the shelter and caring for the animals. The legislature sought to provide funding to the animal shelter with proceeds from the tobacco tax authorized in Clay County pursuant to section 45-14-244, Ala. Code 1975. It was undisputed that Act No. 2017-65, the appropriation measure at issue, did not receive the vote of two-thirds of all the members elected to each house. The Clay County Commission argued that that portion of Act No. 2017-65 purporting to distribute funds to the Clay County General Fund to be disbursed to the animal shelter was, therefore, unconstitutional. After careful consideration, the Alabama Supreme Court concluded the circuit court erred in declaring Act No. 2018-432 as unconstitutional. Judgment was reversed. View "Clay County Animal Shelter, Inc. v. Clay County Commission et al." on Justia Law

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The Alabama Supreme Court granted certiorari review to determine whether the Court of Criminal Appeals erred in affirming a trial court's revocation of Walter McGowan's probation. Probation arose from McGowan's conviction on burglary, assault, obstruction of justice and escape. Before the Court of Criminal Appeals, McGowan asserted that his sentences -- 15 years, split to serve 5 years in prison followed by 2 years' probation -- were illegal sentences because they did not comply with section 15- 18-8(a)(1) or (b), Ala. Code 1975. McGowan argued that, because his split sentences were unauthorized, the trial court had lacked subject-matter jurisdiction to conduct a revocation hearing and to enter an order revoking his probation. Citing Enfinger v. Alabama, 123 So. 3d 535 (Ala. Crim. App. 2012), McGowan argued that, because the trial court had lacked jurisdiction, the probation-revocation order was due to be vacated. The Supreme Court concurred with this reasoning: the trial court was without jurisdiction to conduct probation-revocation proceedings and to enter the probation-revocation order. Therefore, the Court reversed the Court of Criminal Appeals' judgment and remanded the case for further proceedings. View "Ex parte Walter McGowan." on Justia Law

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Plaintiffs Barry Munza, Larry Lewis, and Debbie Mathis appealed a circuit court order dismissing their complaint seeking certain injunctive relief and challenging a proclamation issued by Governor Kay Ivey requiring the use of facial coverings in certain circumstances, as outlined in an order issued by Dr. Scott Harris, the State Health officer, to slow the spread of COVID-19. The Alabama Supreme Court concluded plaintiffs lacked standing to bring their complaint seeking injunctive relief regarding the July 15 proclamation adopting the amended health order that, among other things, required masks or facial coverings to be worn in certain circumstances. Because the Supreme Court determined plaintiffs lacked standing, any discussion of remaining issues was pretermitted. View "Munza, et al. v. Ivey, et al." on Justia Law

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Boone Newspapers, Inc., the Selma Times-Journal, Blake Deshazo, and Will Whaley (collectively termed "the Newspaper defendants") sought mandamus review of a trial court's order denying their motion requesting that Judge Collins Pettaway, Jr., recuse himself from their case. Faya Rose Toure sued the Newspaper defendants, alleging that they defamed her by falsely "indicat[ing] that [Toure] was illegally removing [C]onfederate flags from a public cemetery" and by "falsely report[ing] ... that [Toure] illegally removed a [political] campaign sign from private property." Toure requested compensatory damages and $1 million in punitive damages. The Newspaper defendants filed a summary-judgment motion, which Judge Pettaway denied; he later denied their motion for reconsideration, without a hearing. The Newspaper defendants filed a motion for recusal. The Alabama Supreme Court determined the Newspaper defendants failed to demonstrate that they had a clear legal right to Judge Pettaway's recusal. Accordingly, the Newspaper defendants' petition was denied. View "Ex parte Boone Newspapers, Inc., et al." on Justia Law

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Linda Steinberg, individually and as the sole remaining member and representative of Mendelson Properties, LLC, petitioned the Alabama Supreme Court for a writ of mandamus to direct the Etowah Circuit Court to vacate its order staying the proceedings in her civil case against several defendants. One of the defendants, Lisa Daugherty, moved the trial court to stay discovery regarding discovery requests that had been issued to her on the ground that such a stay was needed to protect her constitutional right against self-incrimination. The trial court granted that motion, but it also stayed the entire case. Because the Supreme Court found the trial court had before it no evidence supporting the stay, the Supreme Court granted the petition and issued the writ. View "Ex parte Linda Steinberg, individually and as sole remaining member and representative of Mendelson Properties, LLC." on Justia Law