Court: Supreme Court of Alabama
Docket: 1190918
Opinion Date: April 2, 2021
Judge: Greg Shaw
Areas of Law: Civil Procedure, Personal Injury
Alexandra Miller, a defendant in this personal injury action, petitioned the Alabama Supreme Court for a writ of mandamus to direct the Madison Circuit Court to vacate its order purporting to grant plaintiff Ralph Mitchell’s post-judgment motion seeking a new trial. Miller and Mitchell were involved in a motor vehicle accident in May 2017. Mitchell sued Miller in the Madison Court, where the matter proceeded to a jury trial in January 2020. At the conclusion of the trial, the trial court granted Mitchell’s motion for a judgment as a matter of law on the issue of liability; the jury subsequently returned a verdict awarding Mitchell damages totaling $22,368, the exact amount of medical expenses that Mitchell alleged at trial. The trial court entered a judgment on the jury’s verdict on January 31, 2020. On February 10, 2020, Mitchell filed a timely post-judgment motion seeking a new trial on the ground that the jury’s verdict allegedly erroneously failed to also include an award for “physical pain and suffering.” The trial court scheduled Mitchell’s motion for a hearing to be held on March 17, 2020. On March 13, 2020, the Alabama Supreme Court, in response to the COVID-19 pandemic, issued an “Administrative Order Suspending All In-Person Court Proceedings for the Next Thirty Days,” i.e., from March 16, 2020, through April 16, 2020. Additional orders further extended the deadline suspending in-person court proceedings. On June 11, 2020, Miller filed a response opposing Mitchell’s post-judgment motion. Subsequent to the scheduled hearing, on June 18, 2020, the trial court entered an order purporting to grant Mitchell’s post-judgment motion seeking a new trial. Miller moved to vacate Mitchell’s motion, arguing the circuit court lacked jurisdiction to grant it. The trial court did not rule on Miller’s motion but set it for a hearing on August 11, 2020, which was more than 42 days after the entry of the June 18, 2020, order purporting to grant Mitchell’s post-judgment motion. The Supreme Court concluded Miller demonstrated both that the trial court lacked jurisdiction to enter the order purporting to grant Mitchell’s post-judgment motion seeking a new trial, and a corresponding clear legal right to the requested relief.
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