Andy Sumblin v. Zachary Ward, as administrator of the Estate of Keith Ward (Appeal from Coffee Circuit Court: CV-19-900012).

CourtCourt of Civil Appeals of Alabama
DecidedJuly 19, 2024
DocketCL-2023-0197
StatusPublished

This text of Andy Sumblin v. Zachary Ward, as administrator of the Estate of Keith Ward (Appeal from Coffee Circuit Court: CV-19-900012). (Andy Sumblin v. Zachary Ward, as administrator of the Estate of Keith Ward (Appeal from Coffee Circuit Court: CV-19-900012).) is published on Counsel Stack Legal Research, covering Court of Civil Appeals of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Andy Sumblin v. Zachary Ward, as administrator of the Estate of Keith Ward (Appeal from Coffee Circuit Court: CV-19-900012)., (Ala. Ct. App. 2024).

Opinion

Rel: July 19, 2024

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is published in Southern Reporter.

ALABAMA COURT OF CIVIL APPEALS SPECIAL TERM, 2024 _________________________

CL-2023-0197 _________________________

Andy Sumblin

v.

Zachary Ward, as administrator of the Estate of Keith Ward

Appeal from Coffee Circuit Court (CV-19-900012)

LEWIS, Judge.

Andy Sumblin appeals from a judgment entered by the Coffee

Circuit Court ("the trial court") in favor of Zachary Ward, as

administrator of the Estate of Keith Ward ("the Estate"). We reverse the

judgment and remand this cause with instructions. CL-2023-0197

Procedural History

On February 20, 2019, Sumblin d/b/a M.O.D. Sod ("Sumblin"), filed

a complaint seeking to collect a debt allegedly owed by Keith Ward d/b/a

Ward Lawn Care ("Ward"). After Ward failed to answer the complaint,

Sumblin filed, on April 11, 2019, a motion seeking an entry of default and

a default judgment. On August 21, 2019, Sumblin filed a summary-

judgment motion. On September 12, 2019, the trial court entered a

judgment; that judgment was amended on that same day. In its final

form, the judgment provided, in pertinent part:

"This matter came before the Court on the Motion for Entry of Default and for Default Judgment filed by [Sumblin] on April 11, 2019…. Having considered the Motion and all matters brought before the Court and for good cause shown, it is hereby ORDERED ADJUDGED and DECREED as follows:

"1. The Motion for entry of default is GRANTED.

"2. The Motion for default judgment is GRANTED and a final default judgment is ENTERED in favor of … Sumblin and against … Ward in the amount of Thirteen Thousand Two Hundred Forty-Three and 74/100 Dollars ($13,243.74), plus costs."

(Capitalization in original.)

Over two years later, on January 6, 2022, "the Estate of Keith

Ward" filed a motion seeking to vacate the trial court's judgment

2 CL-2023-0197

pursuant to Rule 60(b)(6), Ala. R. Civ. P., along with exhibits in support

of the motion. On March 24, 2022, Sumblin filed a response in opposition

to the Rule 60(b)(6) motion and moved the trial court to strike the

exhibits attached thereto. On March 25, 2022, the Estate responded to

Sumblin's March 24, 2022, filing.

After a hearing on March 29, 2022, the trial court entered an order

on April 6, 2022, vacating the September 12, 2019, judgment. On April

15, 2023, Sumblin filed a suggestion of the death of Ward and a motion

requesting that the Estate be substituted as the defendant. That motion

was granted on April 18, 2022. An answer to the complaint was

thereafter filed on September 14, 2022. After a trial, the trial court

entered a judgment on February 17, 2023, providing:

"This matter came before the Court for bench trial on [Sumblin's] complaint seeking damages for an unpaid debt owed by Defendant Ward Lawn Care and Defendant Ward. Upon considering the evidence[,] the Court awarded damages to [Sumblin] in the amount of $12,091.39.

"[Sumblin] sought damages for an unpaid debt of $8,594.95, plus interest[,] attorney fees, and court costs. Because the evidence showed [Ward] was likely incompetent beginning in November 2017, the Court declined to award damages for interest accrued past December 2017.

"The evidence showed … Ward … owned and operated a lawn care business, Ward's Lawn Care. [Sumblin's] business

3 CL-2023-0197

records indicated [Ward] purchased sod for several years and routinely paid the bill after an invoice was sent to [Ward]. During late 2017, [Ward] became delinquent on paying his bill. [Sumblin] mailed [Ward] several invoices and a letter demanding payment. Despite the debt owed, [Ward] did not respond to the letter and [Sumblin] continued to sell sod to [Ward]. [Sumblin] filed suit and [Ward] failed to answer. A default judgment was entered against [Ward] but was later set aside after the Court learned [Ward] had become stricken with brain cancer and had died. The evidence showed [Ward] likely lacked sound mental capacity after he underwent two surgeries to remove a brain tumor. Testimony showed [Ward] began experiencing symptoms of confusion, memory loss, and paralysis during the same time he uncharacteristically failed to pay his bills. Because the evidence showed [Ward's] mental capacity began to fail in November 2017, the Court finds [Ward] should not be liable for interest accrued after December 2017.

"[Sumblin] requested the … [E]state be liable for the unpaid debt. The evidence showed [Ward] purchased sod on behalf of his business, 'Ward's Lawn Care.' [Ward] paid for the sod using checks labeled with the company’s name[,] 'Ward's Lawn Care.' [Sumblin] provided business records showing that 'Ward's Lawn Care' owed the debt. [Sumblin's] sod farm manager testified [Ward] purchased sod at the reduced merchant rate because he owned and operated a landscape company, 'Ward's Lawn Care.' Finally, the [Estate] provided evidence showing [Ward] had properly registered the lawn care business, 'Ward's Lawn Care' with the Alabama Secretary of State.

"Alabama appellate courts have held that 'permitting the piercing of the corporate veil is not a power that is lightly exercised. The concept that a corporation is a legal entity existing separate and apart from its shareholders is well settled in this state.' Co-Ex Plastics, Inc. v. AlaPak, Inc., 536 So. 2d 37 (Ala. 1988). Alorna Coat Corp. v. Behr, 408 So. 2d

4 CL-2023-0197

496 (Ala. 1981). The Courts have established that 'the corporate veil may be pierced where a corporation is set up as a subterfuge, where shareholders do not observe the corporate form, where the legal requirements of corporate law are not complied with, where the corporation maintains no corporate records, where the corporation maintains no corporate bank account, where the corporation has no employees, where corporate and personal funds are intermingled and corporate funds are used for personal purposes, or where an individual drains funds from the corporation.' See, e.g., Forester & Jerue, Inc. v. Daniels, 409 So. 2d 830 (Ala. 1982); Hamrick v. First National Bank of Stevenson, 518 So. 2d 1242 (Ala. 1987); Deupree v. Ruffino, 505 So. 2d 1218 (Ala.1987); Messick v. Moring, 514 So. 2d 892 (Ala. 1987); East End Memorial Association v. Egerman, 514 So. 2d 38 (Ala. 1987).

"While the Court recognizes [Sumblin] is owed a significant unpaid debt, this Court is reluctant to create the slippery slope precedent of piercing the corporate veil based on the evidence presented in this case. Upon consideration of the foregoing, it is ORDERED, ADJUDGED, and DECREED:

"1. The Court finds in favor of [Sumblin] and against Defendant Ward's Lawn Care.

"2. [Sumblin] is awarded damages in the amount of $12,091.39. (The total damages were calculated as follows: $8,594.95 unpaid debt: plus $388.92 in finance charges through December 2017; plus $412.36 court costs: plus $2,695.16 attorney fee calculated by figuring 30% of unpaid debt.)

"3. The Court denies [Sumblin's] request to find …Ward or his estate individually liable."

"4.

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Bluebook (online)
Andy Sumblin v. Zachary Ward, as administrator of the Estate of Keith Ward (Appeal from Coffee Circuit Court: CV-19-900012)., Counsel Stack Legal Research, https://law.counselstack.com/opinion/andy-sumblin-v-zachary-ward-as-administrator-of-the-estate-of-keith-ward-alacivapp-2024.