The case arose from Alabama homeowners' claims against State Farm and its agent for breach of contract, bad faith, fraud, and negligent supervision after the insurer denied coverage for wind damage to a boat dock under a 1996 policy. Defendants removed the action to federal court under diversity jurisdiction, asserting that the Alabama agent had been fraudulently joined because he played no role in selling the policy and that plaintiffs' deposition testimony established more than $75,000 in controversy through lost property value. The court denied the motion to remand, holding that the undisputed facts showed fraudulent joinder and that the amount-in-controversy requirement was met by a preponderance of the evidence.
In McCall v. Montgomery Housing Authority, a tenant of Section 8 federally subsidized housing brought claims under 42 U.S.C. § 1983 against the local housing authority and several employees, alleging violations of her due process rights and federal housing law under the U.S. Housing Act of 1937, along with related Alabama state law claims for breach of contract and negligence arising from an attempted termination of her benefits. The court addressed motions for summary judgment from defendant Clevette Ellis and from the authority along with defendants Hester and Harris. Applying the standard under Federal Rule of Civil Procedure 56, the court granted Ellis's motion in full due to lack of factual or legal basis for claims against her, and granted the other motion in part and denied it in part where genuine disputes of material fact remained on certain claims.
The case concerned K.I., a student with arthrogryposis and other medical conditions, whose parents challenged an administrative ruling that Montgomery Public Schools had provided her a free appropriate public education under the IDEA by placing her in a self-contained school for medically fragile children rather than a mainstream setting. The parents sought reversal of that decision along with relief under Section 504 of the Rehabilitation Act, claiming inadequate evaluations, lack of assistive technology, insufficient academic and self-care services, and failure to offer mainstreaming or timely homebound instruction. The district court granted the school district’s motion in part and denied it in part, denied the parents’ motion for partial summary judgment on the Section 504 claims, and granted in part and denied in part the parents’ motion to reverse the administrative decision, finding that the record supported some but not all of the hearing officer’s conclusions regarding the least restrictive environment and offered services.
This case arose from a fatal car collision during a high-speed police pursuit on U.S. Highway 231, where officers including Ozark Police Sergeant Jimmy Culbreath chased suspect Ronald Charles Pugh in the wrong direction on the highway after attempting a warrantless search, resulting in Pugh's vehicle striking and killing Charles Edward Knight. The plaintiff, as administratrix of Knight's estate, brought claims under 42 U.S.C. § 1983 alleging violations of the decedent's Fourth and Fourteenth Amendment rights against Culbreath and the City of Ozark, plus related state-law tort claims, asserting that the officers' reckless actions and municipal policies caused the crash. The court granted the motion to dismiss filed by Culbreath and the City of Ozark, holding that Culbreath was entitled to qualified immunity on the federal claims because he acted within his discretionary authority without violating clearly established constitutional rights and that state-agent immunity barred the tort claims against both defendants.
The case involved employees of Alabama's Department of Mental Health & Mental Retardation suing the Department in state court for unpaid overtime compensation under the Fair Labor Standards Act, with the suit later removed to federal court. The Department moved to dismiss for lack of subject matter jurisdiction, asserting Eleventh Amendment sovereign immunity as a state agency. The court granted the motion, ruling that the Department was entitled to immunity from private FLSA damages suits and that its voluntary removal of the case did not waive that immunity under existing Eleventh Circuit precedent. The core reasoning was that the Eleventh Amendment bars federal jurisdiction over such claims against unconsenting states, and the court declined to broaden the limited Lapides waiver rule to this situation where the state had not already consented to suit in its own courts.
The case involves an employment dispute in which plaintiff Claude Short, a white American male formerly employed as Quality Director at defendant Mando American Corporation (MAC), alleged race and national origin discrimination, harassment, retaliation, and related state-law tort claims arising from his demotion, transfer, and eventual termination. MAC moved for summary judgment, contending that Short's performance issues with Korean-managed suppliers and his refusal to accept a relocation package justified the employment actions. The court granted summary judgment to MAC on the § 1981 claims to the extent they were based on national origin, holding that the statute does not authorize such claims. It also accepted MAC's articulation of legitimate, nondiscriminatory reasons for the demotion/transfer and termination decisions, noting that Short failed to create a triable issue of pretext. Various evidentiary motions to strike were addressed in connection with these rulings.