Charles Lynwood Smith jr

This case concerned the Jefferson County Board of Education's request for an injunction to block enforcement of an administrative order under the Individuals with Disabilities Education Act (IDEA) that would have allowed a student, J.B., who was expelled for bringing a handgun to school, to attend his high school graduation ceremony at Clay-Chalkville High School. The hearing officer had ruled that excluding the student from commencement would deny him a free appropriate public education (FAPE). The court granted the injunction, determining that the hearing officer's decision was erroneous because participation in graduation was not part of FAPE and was denied under a generally applicable disciplinary policy unrelated to the student's disability, the burden of persuasion had been improperly reversed, and no evidence showed that the student was deprived of a FAPE by completing his education elsewhere. The ruling rested on the conclusion that the administrative order lacked a proper basis under IDEA.

civil rightsfederal power

This case concerns a challenge by the Alabama Education Association and related plaintiffs to Alabama Act No. 2010-761, which amended state law to prohibit public employees, including school board staff, from arranging salary deductions for payments to political action committees or for membership dues in organizations that use any portion of those funds for political activities, while also expanding criminal penalties under election offense statutes. The court granted the plaintiffs' motion for a preliminary injunction, preventing the Act from taking effect. The decision rested on findings that the Act's language was unconstitutionally vague, creating uncertainty about what conduct was criminalized and likely chilling protected First Amendment rights of speech and expressive association for employees and organizations. The court further noted that longstanding statutes had previously permitted such voluntary deductions without these restrictions, and the new provisions risked overbroad application to non-political activities.

electionscriminal lawlabor & employmentfree speech

Peter Johnson, a Seventh-Day Adventist employee at AutoZone, sued his employer under Title VII for failure to accommodate his religious beliefs against working on the Sabbath (from Friday sundown to Saturday sundown), as well as claims of religious discrimination, harassment, and retaliation. The case reached the court on AutoZone's motion for summary judgment. After reviewing the parties' evidence and applying the summary judgment standard under Federal Rule of Civil Procedure 56, the court granted the motion in full. It determined that Johnson failed to show genuine disputes of material fact on any claim, including that he had engaged in protected activity for the retaliation claim or that AutoZone's policies and actions violated Title VII.

labor & employmentcivil rightsreligious liberty

In Tucker v. City of Florence, Ala., plaintiff Brenda Hawkins Tucker sued the City of Florence, Myron Crunk, and Timothy Glover under 42 U.S.C. § 1983, alleging that her arrest and prosecution on drug-related charges in 2007 violated her Fourth and Fourteenth Amendment rights through malicious prosecution, arrest without probable cause, and abuse of legal process; she also brought supplemental Alabama state-law claims for malicious prosecution, libel, abuse of process, and invasion of privacy. The claims stemmed from an investigation into whether Tucker, a drug rehabilitation facility operator with a history of addiction, had engaged in "doctor shopping" for opioids while managing her medical conditions. The court granted the defendants' motion for summary judgment on all federal claims. It then declined to exercise supplemental jurisdiction over the state-law claims, resulting in dismissal of the action in its entirety.

criminal lawcivil rightsproceduretorts & liability

In Alexander v. City of Muscle Shoals, Alabama, plaintiff Stephen Alexander sued the city and various officials under 42 U.S.C. § 1983 after his nine-day detention in the municipal jail following an arrest for public intoxication, alleging deliberate indifference to his serious medical needs as a pretrial detainee and failure to provide a prompt judicial appearance, both in violation of the Fourteenth Amendment's Due Process Clause, along with related state-law negligence claims. The district court granted defendants' motion for summary judgment on all federal claims. The court concluded that plaintiff had not shown a violation of clearly established constitutional rights, entitling officials to qualified immunity, and declined to exercise supplemental jurisdiction over the remaining state-law claims while denying the other pending motions as moot.

civil rightscriminal lawfederal powerprocedure

This case involves former hourly employees at a poultry processing plant suing two human resources personnel under the civil RICO statute, alleging a conspiracy to knowingly hire and harbor large numbers of illegal immigrants in order to depress wages of legal workers. Plaintiffs based their claims on predicate violations of the Immigration and Nationality Act, specifically provisions criminalizing the knowing hiring of at least ten unauthorized aliens and the harboring or shielding of illegal immigrants for financial gain. The court addressed pending motions for summary judgment, exclusion of expert witnesses on damages and causation, and requests for additional discovery. The decision turned on whether plaintiffs could produce reliable expert evidence and admissible facts establishing the required predicate acts, pattern of racketeering, and proximate injury to their wages, with the opinion examining the sufficiency of the record on these elements.

immigrationcriminal lawlabor & employment

The case involves plaintiff Kevin Penn, an African-American employee at USF Holland, Inc., who asserted claims under Title VII and 42 U.S.C. § 1981 for race-based disparate treatment, hostile work environment, and retaliation. The defendant employer moved for summary judgment, submitting evidence of workplace incidents, grievances filed by Penn, and management actions at the Decatur terminal. The court reviewed the record under Federal Rule of Civil Procedure 56 standards, drawing all reasonable inferences in Penn's favor but finding no genuine issue of material fact on any claim. It therefore granted summary judgment to the defendant on all claims, concluding the evidence was insufficient for a reasonable jury to return a verdict for the plaintiff.

civil rightslabor & employment

The case involved a lawsuit by the estate of James Anthony Lard against McNeilus Truck and Manufacturing, Inc., after Lard fell from the riding platform of a garbage truck made by the defendant and died. The plaintiff brought claims under Alabama's Extended Manufacturer’s Liability Doctrine and implied warranties of merchantability and fitness. The court excluded the testimony of the plaintiff's expert witness, Dr. L.D. Ryan, finding him unqualified and his opinions unreliable under Federal Rule of Evidence 702 and Daubert standards. Without admissible expert evidence, the court granted summary judgment to the defendant on all claims, as the plaintiff could not support the necessary elements.

torts & liabilityprocedure

This case is an appeal from a bankruptcy court summary judgment ruling that David Blain Carroll could not discharge his personal liability for estate taxes owed by his deceased father's estate. The district court conducted a de novo review of the bankruptcy court's decision and affirmed the holding that the tax debt is excepted from discharge under 11 U.S.C. § 523(a)(1)(C). The court applied the legal standards for summary judgment in bankruptcy cases, including the absence of genuine issues of material fact, and concluded based on the record that the debt remained nondischargeable.

taxesprocedure

The case involves a habeas corpus petition filed by Alabama death row inmate Kenneth Glenn Thomas, who was convicted of capital murder during a burglary and sentenced to death. After most claims were dismissed, the sole remaining issue was whether Thomas is mentally retarded, which would require vacating his death sentence under Atkins v. Virginia. The court conducted an evidentiary hearing to assess whether Thomas proved by a preponderance of the evidence that he had significantly sub-average intellectual functioning and substantial deficits in adaptive behavior during the developmental period before age 18. Respondent conceded Thomas's current IQ falls in the mild mental retardation range but disputed the historical evidence from childhood and adolescence. The opinion evaluates historical IQ tests, expert testimony on standardized assessments, the Flynn Effect, and adaptive behavior records to address that question.

criminal law

This case is a sequel to prior litigation over desegregation of Alabama's higher education system, in which plaintiffs now challenge six provisions of the 1901 Alabama Constitution that limit ad valorem property tax rates, assessments, and voter approval requirements for counties, municipalities, and schools. Plaintiffs, including African American students and parents, contend these limits are traceable to discriminatory origins, underfund K-12 education, and perpetuate segregative effects on school choice. Defendants moved to dismiss for lack of subject matter jurisdiction, invoking principles such as comity that require federal courts to defer to state courts on challenges to state tax laws. The court recounts the factual and procedural history, including prior findings that the tax structure has discriminatory antecedents but an attenuated link to higher education desegregation, while noting that comity arguments must be supported by legal authority.

civil rightstaxesfederal powerproperty

This case involves plaintiffs suing moving companies in Alabama state court for property damage and mental anguish after their furniture was allegedly damaged during an interstate shipment from New York to Alabama. Defendant Atlas Van Lines removed the action to federal court and moved to dismiss on grounds that the claims are preempted by the Carmack Amendment to the Interstate Commerce Act. Before considering the motion, the court raised subject-matter jurisdiction concerns sua sponte, noting that the complaint does not specify damages exceeding the $10,000 threshold required for removal under 28 U.S.C. § 1445(b) and that the Carmack Amendment may not completely preempt state-law claims given statutory provisions reserving some such actions for state courts. The court ordered the defendant to brief why the case should not be remanded and gave plaintiffs an opportunity to respond.

procedurefederal powerbusiness & regulatory

Pamela Moore sued Sara Lee Foods, Inc., alleging racial discrimination and wrongful discharge under Title VII and 42 U.S.C. § 1981. After the defendant moved for summary judgment and the pro se plaintiff's responses were struck for noncompliance with court orders, the court deemed the defendant's facts admitted but independently reviewed the record. The court granted summary judgment, concluding that Moore had named the wrong defendant because the entity sued was not her employer, and that her claims failed on the merits for lack of evidence supporting discrimination, a prima facie case, pretext, or a hostile work environment.

civil rightslabor & employmentprocedure

In Scheuerman v. City of Huntsville, the plaintiff sued an off-duty police officer employed as a bank fraud investigator and the city after sustaining serious injuries during a shooting incident that arose from a traffic encounter involving an unmarked vehicle. The plaintiff asserted federal constitutional claims under 42 U.S.C. § 1983 along with supplemental state-law claims for assault and battery, unlawful detention, and negligence. On the defendants' motions for summary judgment, the court reviewed the record under Federal Rule of Civil Procedure 56(c) to determine whether any genuine issue of material fact existed, while assessing the officer's qualified immunity defense by viewing the facts in the light most favorable to the plaintiff to decide whether a violation of clearly established law had occurred.

civil rightsproceduretorts & liability

This case was an ERISA action between Johnson and Blue Cross and Blue Shield of Alabama. The district court had previously granted summary judgment to the plaintiff and denied the defendant's motion. After the defendant appealed to the Eleventh Circuit, the parties settled the dispute during mediation and filed a joint motion to vacate the judgment under Federal Rule of Civil Procedure 60(b). Following the Eleventh Circuit's remand and instructions in Mahone v. Ray, the court granted the motion to vacate its prior ruling, set aside the judgment in the plaintiff's favor, and denied the summary judgment motions as well as related fee motions as moot.

procedure

This ERISA case involved plaintiff LeeAnn Johnson, a beneficiary under a group health plan administered by defendant Blue Cross and Blue Shield of Alabama, who sought coverage for bariatric surgery recommended for her morbid obesity after the insurer denied the claim by labeling the procedure investigational and thus excluded under the policy. On cross-motions for summary judgment, the court granted judgment to the plaintiff and denied the defendant's motion, while also denying as moot the defendant's motion to strike certain evidence. The court reasoned that the Summary Plan Description's exclusion for investigational treatments did not apply because medical literature, policy statements from other insurers, and expert evidence established the Roux-en-Y gastric bypass procedure as a standard, non-investigational treatment that improves net health outcomes for patients with morbid obesity. The decision turned on interpreting the plan's terms and reviewing the administrative record without needing additional evidentiary submissions.

healthcare

In United States v. Hyde, defendant Samuel Steven Hyde was sentenced in 2004 to 70 months in prison for receiving and possessing child pornography under 18 U.S.C. § 2252A after pleading guilty; his judgment included an alternative 16-month sentence to apply if the U.S. Sentencing Guidelines were later ruled unconstitutional following Blakely v. Washington. After the Supreme Court's decision in United States v. Booker made the Guidelines advisory rather than mandatory, Hyde moved to amend the judgment to impose the shorter alternative sentence. The court denied the motion, holding that the alternative sentence was conditioned on a complete invalidation of the Guidelines requiring all facts to be found by a jury beyond a reasonable doubt, whereas Booker preserved judicial fact-finding under an advisory regime and did not trigger the alternative. The core reasoning focused on the limited scope of the alternative language, which was drafted during the post-Blakely uncertainty period but did not encompass Booker's actual outcome.

criminal lawprocedure

This case concerns Avocent Huntsville Corporation's allegations that ClearCube Technology, Inc.'s products infringe claims in two patents (the '997 and '919 patents) related to transmitting analog color video signals over extended distances. ClearCube raised defenses and counterclaims asserting invalidity under 35 U.S.C. §§ 102, 103, and 112, as well as unenforceability due to inequitable conduct during patent prosecution. The opinion addresses numerous pending motions for summary judgment on issues including whether certain references qualify as prior art, whether the patents are invalid or unenforceable, whether specific claim limitations such as an 'amplifier' or 'adapter' are met by the accused products, and claim construction. The court outlines standards of review, provides background on the patents, analyzes expert reports, and resolves aspects of the infringement and validity disputes through its rulings on the motions.

business & regulatoryprocedure

The case centered on plaintiff Domer L. Ishler's dispute with the IRS Commissioner, an IRS agent, and NSA over his federal income tax liability arising from revenue in a business transaction involving NSA. Ishler, proceeding pro se, asserted claims for a declaratory judgment granting him a tax credit for withheld funds, damages for breach of fiduciary duty, a tax refund, plus additional unenumerated claims including fraud, breach of contract, conspiracy, and treble damages under an Alabama statute. The defendants moved to dismiss under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6) for lack of subject matter jurisdiction and failure to state a claim. The court granted the motions, holding that tax-related claims were barred by the Anti-Injunction Act and Declaratory Judgment Act, other claims were time-barred by statutes of limitations, and remaining allegations failed to state viable causes of action.

taxesprocedurefederal powerbusiness & regulatory

The case concerned a substantive due process challenge by vendors and users of sexual devices to an Alabama statute that criminalizes their commercial distribution, with plaintiffs claiming the law unduly burdens rights of privacy and personal autonomy under the Fourteenth Amendment or lacks any rational basis. Following multiple prior rounds of litigation, the district court applied Eleventh Circuit precedent holding that the asserted interests do not qualify as fundamental rights. The court reasoned that substantive due process protections are limited to rights deeply rooted in history and tradition or implicit in ordered liberty, that public morality remains a legitimate state interest supporting the ban, and that the statute therefore survives rational-basis review.

criminal lawcivil rights