Ex parte City of Birmingham PETITION FOR WRIT OF MANDAMUS: CIVIL (In re: Nicholas Raynard Smith, Jr. v. City of Birmingham) (Jefferson Circuit Court: CV-21-901781).

CourtSupreme Court of Alabama
DecidedSeptember 19, 2025
DocketSC-2024-0700
StatusPublished

This text of Ex parte City of Birmingham PETITION FOR WRIT OF MANDAMUS: CIVIL (In re: Nicholas Raynard Smith, Jr. v. City of Birmingham) (Jefferson Circuit Court: CV-21-901781). (Ex parte City of Birmingham PETITION FOR WRIT OF MANDAMUS: CIVIL (In re: Nicholas Raynard Smith, Jr. v. City of Birmingham) (Jefferson Circuit Court: CV-21-901781).) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ex parte City of Birmingham PETITION FOR WRIT OF MANDAMUS: CIVIL (In re: Nicholas Raynard Smith, Jr. v. City of Birmingham) (Jefferson Circuit Court: CV-21-901781)., (Ala. 2025).

Opinion

Rel: September 19, 2025

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 printed in Southern Reporter.

SUPREME COURT OF ALABAMA SPECIAL TERM, 2025

_________________________

SC-2024-0700 _________________________

Ex parte City of Birmingham

PETITION FOR WRIT OF MANDAMUS

(In re: Nicholas Raynard Smith, Jr.

v.

City of Birmingham)

(Jefferson Circuit Court: CV-21-901781)

McCOOL, Justice. SC-2024-0700

The City of Birmingham ("the City") has petitioned this Court for a

writ of mandamus, asking us to direct the Jefferson Circuit Court to enter

a summary judgment in the City's favor with respect to the claims that

Nicholas Raynard Smith, Jr., has asserted against it.

Facts and Procedural History

At approximately 9:30 p.m. on June 23, 2019, John Daniels, Jr., was

driving south through Birmingham on Interstate 59 ("I-59"). While

Daniels was driving in the left-hand lane, an automobile in the lane to

his right struck the right side of his black Toyota Camry, which caused

Daniels to lose control of his car and crash into the concrete median that

separates the northbound and southbound lanes of I-59. There are

streetlights spaced along that concrete median, and Daniels's car came

to rest "somewhere between [streetlights] W066 and W067." "[R]ight

after that, cars just started hitting [Daniels's] car" "back to back to back."

At the time of Daniels's accident, Smith and his friend Keith

Holiness were traveling southbound on their motorcycles in the left-hand

lane of I-59. Both men were traveling at or slightly above the 60-mile-

per-hour speed limit, and both had their headlights turned on. Smith

and Holiness reached the accident site almost immediately after

2 SC-2024-0700

Daniels's car struck the concrete median; in fact, Holiness saw at least

two collisions in that accident occur and testified in his deposition that

the accident "was still going on" as he and Smith approached it. Holiness

first noticed the accident when he was approximately 70 yards from it,

and, according to Holiness, Smith noticed it "probably about the same

time." Holiness swerved to the right of the cars that had been involved

in the accident, but he struck the bumper of one of those cars, which sent

him into "a high speed wobble." Holiness ultimately managed to bring

his motorcycle to a stop a little further down I-59. Smith has no

recollection of the accident, but, according to Holiness, Smith "hit the

brakes" when he saw the accident but was unable to avoid colliding with

Daniels's car. Smith suffered extensive injuries as a result of his

accident, including "head trauma, facial injuries, injuries to his teeth, a

fracture of the malar and maxillary bones, a foot fracture, a fractured

pelvis, a pulmonary collapse, and other injuries."

It is undisputed that, when first responders arrived at the scene of

the accident, "[street]lights … W066 … and W067 … were not

operational." However, there is conflicting evidence as to whether those

streetlights had been operational at the time of Daniels's accident.

3 SC-2024-0700

According to Daniels, "the interstate lights were on that night before the

accident," but he did not "actually look up any time before th[e] accident

to observe which lights were working" and thus "could not give definitive

testimony as to which light bulbs … were on or off at the time of [his]

accident." Tommie Stinson, the City's division manager for signals and

streetlights, testified in his deposition that the fact that streetlights

W066 and W067 were not operational when first responders arrived did

not necessarily mean that those streetlights had been inoperable at the

time of Daniels's accident. According to Stinson, "[Daniels's] accident

could have caused [streetlights W066 and W067] to go out" because "the

wiring is in the median," so there "can be a hard enough impact [to the

median] where it can shake and rattle the wiring in the pole itself and

cause a short and malfunction in the circuit." Holiness testified in his

deposition, however, that "[t]he [street]lights weren't on" when he and

Smith "got on the interstate," and, although Smith has no recollection of

his accident, he testified in his deposition that a "lighting problem" had

existed at that part of I-59 "for years."

James Greer Fowler, the director of the City's Department of

Transportation, testified in his deposition that it was "[his]

4 SC-2024-0700

understanding … that the City … is responsible for the maintenance of

the lighting" on that part of I-59 where Smith's accident occurred, and,

according to Fowler, in April 2019 the City "undertook a significant

project to replace and upgrade the light fixtures along that section of the

interstate." That project was necessary, Fowler explained, because "some

fixtures … were not working along that corridor, and also the type of

fixtures that were along that corridor were outdated and really needed to

be upgraded to more modern LED fixtures." Fowler also testified that,

at the time of Smith's accident, the City's replacement project "had gotten

to and beyond th[e] point where [Smith's accident] occurred."

Stinson testified in his deposition that the streetlights on I-59 were

functioning properly following the City's April 2019 replacement project

and that he had received "no notification from anyone that the lights were

not working." Stinson acknowledged that, following the City's

replacement project, there had briefly been "a breaker problem" and "two

bad fuses" that had resulted in some inoperable streetlights, including

streetlights W066 and W067. However, Stinson testified that those

problems had been addressed on April 29, 2019, and that he had not

5 SC-2024-0700

received any notice "that there was a problem with … light fixtures W061

through W070 … after that."

In June 2021, Smith filed a complaint against the City, asserting

claims of negligence, wantonness/recklessness, and negligent/wanton

hiring, training, supervision and/or retention. 1 According to Smith, the

City "owed a duty to [him] … and all other motorists traveling on I-59 to

ensure the interstate lights were maintained, repaired, and operable and

to exercise reasonable care and due care maintaining the lights so [they]

were working properly." Smith also alleged that the City "knew or should

1Smith also asserted "claims" of "respondeat superior" and "fictitious parties." However, the doctrine of "respondeat superior" is a theory of liability, not a legal claim. See O'Bryan v. Holy See, 556 F.3d 361, 370 n.1 (6th Cir. 2009) ("Plaintiffs also plead a separate cause of action titled 'Respondeat Superior Liability.' However, respondeat superior is not a cause of action. It is a basis for holding the [defendant] responsible for the acts of its agents."); Holford v. DiFabio, No. 21-02261, Dec. 6, 2021 (E.D. Pa.

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Ex parte City of Birmingham PETITION FOR WRIT OF MANDAMUS: CIVIL (In re: Nicholas Raynard Smith, Jr. v. City of Birmingham) (Jefferson Circuit Court: CV-21-901781)., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ex-parte-city-of-birmingham-petition-for-writ-of-mandamus-civil-in-re-ala-2025.