Adams v. HGC Riverchase LLC

District Court, N.D. Alabama·Decided September 3, 2025·No. 2:23-cv-01540·Unknown

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

ELAINE ADAMS, } } Plaintiff, } } v. } Case No.: 2:23-cv-01540-RDP } HGC RIVERCHASE, LLC, } } Defendant. }

MEMORANDUM OPINION AND ORDER This matter is before the court on Defendant HGC Riverchase, LLC’s (“HGC”) Motion to Reconsider, Alter, Amend, or, in the Alternative, to Certify. (Doc. # 67). The Motion has been fully briefed. (Docs. # 67, 70, 71). For the reasons discussed below, the Motion (Doc. # 67) is due to be denied. I. Background This case involves the tragic death of Plaintiff’s eighteen-year-old son Reginald Adams (“Adams”) who drowned after going down a slide into the pool at the Riverchase Country Club (“RCC”) on August 22, 2023. Following the death of her son, Plaintiff filed this action asserting the following claims in her Amended Complaint: (Count One) negligence and (Count Two) wantonness. (Doc. # 28). Plaintiff alleges that pursuant to the Shelby County Regulations, HGC owed Adams a duty to provide lifeguards and safety equipment at the RCC pool and that HGC negligently and wantonly breached this duty. (Id.). HGC filed a Motion for Summary Judgment arguing that it was entitled to summary judgment on both Plaintiff’s negligence and wantonness claims. (Doc. # 46). On June 25, 2025, the court entered a Memorandum Opinion and Order granting in part and denying in part HGC’s Motion for Summary Judgment. (Docs. # 65, 66). The court denied HGC’s request for summary judgment as to Plaintiff’s negligence claim based on the lack of lifeguards. (Docs. # 65 at 13; 66). However, the court granted HGC’s requests for summary judgment as to Plaintiff’s negligence claim based on the lack of safety equipment and Plaintiff’s

wantonness claim. (Docs. # 65 at 14-15; 66). The court dismissed those claims with prejudice. (Doc. # 66). On July 14, 2025, HGC filed its Motion to Reconsider Alter, Amend, or, in the Alternative, to Certify requesting that the court “reconsider, alter, or amend its Order denying HGC’s Motion for Summary Judgment on [Plaintiff’s] negligence claim as it relates to lifeguards, or, in the alternative, to certify the legal question to the Supreme Court of Alabama.” (Doc. # 67 at 1). II. Discussion A. Motion to Reconsider The grant or denial of a motion to reconsider is left to the discretion of the district court.

See Chapman v. AI Transport, 229 F.3d 1012, 1023-24 (11th Cir. 2000). Motions for reconsideration are a disfavored, extraordinary remedy that should be employed sparingly. See, e.g., Iberiabank v. Case Constr., LLC, 2015 WL 5457889, at *2 (S.D. Ala. 2015) (“Motions to reconsider are disfavored in federal court and are granted only in narrowly circumscribed circumstances.”). As this court has explained, a motion to reconsider is not a vehicle to relitigate old matters, assert novel arguments, or present evidence that could have been raised previously: Far too often, litigants operate under the flawed assumption that any adverse ruling . . . confers upon them license to move for reconsideration, vacatur, alteration or amendment as a matter of course, and to utilize that motion as a platform to criticize the judge’s reasoning, to litigate issues that have already been decided, to champion new arguments that could have been made before, and otherwise to attempt a “do- over” to erase a disappointing outcome. This is improper.

Garrett v. Stanton, 2010 WL 320492, *2 (S.D. Ala. 2010); see also Michael Linet, Inc. v. Vill. of Wellington, Fla., 408 F.3d 757, 763 (11th Cir. 2005) (finding that a motion to reconsider may not be used to “relitigate old matters, raise argument[s] or present evidence that could have been raised prior to the entry of judgment.”); Hughes v. Stryker Sales Corp., 2010 WL 2608957, *2 (S.D. Ala. 2010) (rejecting notion that motions to reconsider “are appropriate whenever the losing part thinks the [d]istrict [c]ourt got it wrong.”). Motions to reconsider “cannot be brought solely to relitigate issues already raised.” Harris v. Corrs. Corp. of Am., 433 F. App’x 824, 825 (11th Cir. 2011). Instead, as a general rule, “[a] motion to reconsider is only available when a party presents the court with evidence of an intervening change in controlling law, the availability of new evidence, or the need to correct clear error or manifest injustice.” Busby v. JRHBW Realty, Inc., 2006 WL 8446617, at *1 (N.D. Ala. 2006); see also Harris, 433 F. App’x at 825. Because HGC’s request for reconsideration centers around a prior ruling, the court briefly summarizes the applicable caselaw and the inquiry relevant to its prior decision before evaluating HGC’s arguments. Under Alabama law, to establish a negligence claim a plaintiff must show: “(1) a duty to a foreseeable plaintiff; (2) a breach of that duty; (3) proximate causation; and (4) damage or injury.” Lemley v. Wilson, 178 So. 3d 834, 841 (Ala. 2015) (internal quotation marks omitted). In Lands v.

Ward, the Supreme Court of Alabama held that “[i]n a negligence action, it is possible for a legal duty imposed by statute or regulation to inform the common-law standard of reasonable care or to supplant it entirely.” 349 So. 3d 219, 223 (Ala. 2021) (citing Parker Bldg. Servs. Co. v. Lightsey ex rel. Lightsey, 925 So. 2d 927, 930-31 (Ala. 2005)). It went on to state that “[a] violation of a [safety] statute or ordinance can, therefore, be evidence of negligence under certain circumstances.” Id. (quoting Murray v. Ala. Power Co., 413 So. 2d 1109, 1114 (Ala. 1982)) (alteration in Lands). Specifically, the court explained that while negligence per se uses a statutory violation to “conclusively establish, as a matter of law, duty and breach[,]” a general negligence claim merely

uses a “statute to make out a prima facie case of negligence.” Id. at 223 n.1 (citations omitted). The court emphasized that the use of a statute in a general negligence claim “is not to be confused with the doctrine of negligence per se.” Id. And in Lands, the Supreme Court of Alabama found that because the defendant “was required under both federal regulations and Alabama statute to ‘systematically inspect, repair, and maintain, or cause to be systematically inspected, repaired, and maintained, all motor vehicles . . . subject to its control[,]’” the plaintiff was “entitled to use the regulations and the statute incorporating them into Alabama law to establish his prima facie case for negligence.” Id. at 225. HGC urges the court to reconsider its previous Memorandum Opinion and Order (Docs. #

65, 66) based on “the need to correct clear error or manifest injustice.” (Doc. # 67 at 2 (citing Busby, 2006 WL 8446617, at *1)). HGC asserts that the court “did not recognize analogous legal authority cited in the Rule 56 record” and “overturned substantive Alabama law on HGC’s open and obvious defense.” (Id. at 1). To support its argument, HGC contends that “[a]s a matter of law, the open and obvious defense applies to [Plaintiff’s] negligence claim.” (Id. at 2). HGC relies heavily on Fletcher v. Hale, 548 So. 2d 135 (Ala. 1989) to support its position. HGC asserts that Fletcher “is analogous to the present case because it involves a regulatory duty and a contributory negligence defense.” (Doc. # 67 at 3).

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