Ex parte Robert Holland PETITION FOR WRIT OF MANDAMUS (In re: Ashley M. Moore v. City of Pleasant Grove) (Jefferson Circuit Court, Bessemer Division: CV-22-900141).

CourtSupreme Court of Alabama
DecidedOctober 4, 2024
DocketSC-2024-0345
StatusPublished

This text of Ex parte Robert Holland PETITION FOR WRIT OF MANDAMUS (In re: Ashley M. Moore v. City of Pleasant Grove) (Jefferson Circuit Court, Bessemer Division: CV-22-900141). (Ex parte Robert Holland PETITION FOR WRIT OF MANDAMUS (In re: Ashley M. Moore v. City of Pleasant Grove) (Jefferson Circuit Court, Bessemer Division: CV-22-900141).) 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 Robert Holland PETITION FOR WRIT OF MANDAMUS (In re: Ashley M. Moore v. City of Pleasant Grove) (Jefferson Circuit Court, Bessemer Division: CV-22-900141)., (Ala. 2024).

Opinion

Rel: October 4, 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 printed in Southern Reporter.

SUPREME COURT OF ALABAMA SPECIAL TERM, 2024

_________________________

SC-2024-0345 _________________________

Ex parte Robert Holland

PETITION FOR WRIT OF MANDAMUS

(In re: Ashley M. Moore

v.

City of Pleasant Grove et al.)

(Jefferson Circuit Court, Bessemer Division: CV-22-900141)

SELLERS, Justice. SC-2024-0345

Robert Holland, one of the defendants below, petitions this Court

for a writ of mandamus directing the Jefferson Circuit Court ("the trial

court") to vacate its order denying his motion to dismiss an amended

complaint substituting him as a defendant in the underlying action

brought by Ashley M. Moore and to enter an order dismissing him as a

defendant in that action. We grant the petition and issue the writ.

I. Facts

On September 23, 2021, Pleasant Grove police officers Robert

Holland and Marque Gresham were attempting to apprehend a criminal

suspect who was fleeing in the residential neighborhood in which Moore

resided. During that time, the suspect fired gunshots at the officers, both

of whom fired back. One or more of the bullets discharged in the shooting

entered the home of Moore, who was allegedly injured when she "dove to

protect her young son at which time she fell to the concrete floor and a

television fell on top of them."

On March 22, 2022, Moore commenced an action against the City

of Pleasant Grove ("the City") and fictitiously named defendants, seeking

damages for her alleged injuries. In June 2022, Moore learned through

2 SC-2024-0345

discovery that Holland and Gresham were the officers who had been

involved in the shooting incident.

On September 23, 2023, the final day of the applicable two-year

statute-of-limitations period, Moore filed an amended complaint

substituting Holland and Gresham for fictitiously named defendants in

the original complaint; the complaint included instructions for the circuit

clerk to serve the summonses and the amended complaint on both officers

by certified mail at the addresses listed in the amended complaint. 1 As

explained in detail below, the clerk sent a copy of the summons and the

1Moore used the State's electronic-filing system, Alafile.gov., to commence the underlying action. This Court takes judicial notice that, when a plaintiff uses the electronic-filing system to file an amended complaint adding multiple defendants, the plaintiff can add only one defendant at a time and must enter all information pertaining to that defendant. Once a plaintiff adds a defendant to an underlying action, the plaintiff is prompted to check a box indicating whether the "[p]arty needs to be served." Ultimately, if the plaintiff checks the box indicating that the defendant needs to be served and the plaintiff requests service by certified mail by the clerk and pays the required fee for that service, the system automatically generates a summons directed to the defendant. The summons along with the uploaded amended complaint is forwarded to the circuit clerk who, in turn, initiates service of process for that defendant. Notably, after a plaintiff supplies all the necessary information regarding a defendant being added, the system generates an "E-File Receipt." 3 SC-2024-0345

amended complaint to Gresham by certified mail; however, nothing was

sent by the clerk to Holland.

On December 19, 2023, Moore received notice that the certified mail

addressed to Gresham had been returned as unclaimed. On December

28, 2023, Moore supplied the circuit clerk with alias summonses for both

Holland and Gresham, advising that a private process server would be

used to accomplish service.

On January 17, 2024, 116 days after the statute-of-limitations

period had expired, Holland was served by a process server. Holland filed

a motion to dismiss pursuant to Rule 12(b)(6), Ala. R. Civ. P., contending

that he had not been served in the underlying action until after the

statute-of-limitations period had expired. Holland specifically argued

that, at the time Moore filed her amended complaint substituting him as

a named defendant in the underlying action, she had no bona fide

intention of having the amended complaint immediately served.

Following a hearing, the trial court denied the motion to dismiss, without

stating a reason for the denial. This mandamus petition followed.

II. Standard of Review

"A writ of mandamus is an extraordinary remedy available only when the petitioner can demonstrate: ' "(1) a 4 SC-2024-0345

clear legal right to the order sought; (2) an imperative duty upon the respondent to perform, accompanied by a refusal to do so; (3) the lack of another adequate remedy; and (4) the properly invoked jurisdiction of the court." ' Ex parte Nall, 879 So. 2d 541, 543 (Ala. 2003) (quoting Ex parte BOC Grp., Inc., 823 So. 2d 1270, 1272 (Ala. 2001))."

Ex parte Alabama Dep't of Corr., 252 So. 3d 635, 636 (Ala. 2017).

III. Discussion

Holland contends that, at the time Moore filed her amended

complaint substituting him as a named defendant in the underlying

action, she had no bona fide intention of having the complaint

immediately served. Thus, he says, the underlying action against him

could not be considered to have been commenced within the statute-of-

limitations period under Alabama law.2 We agree. A civil action is

commenced upon the filing of a complaint. See Rule 3, Ala. R. Civ. P.

However, the filing of a complaint, standing alone, does not commence an

action for statute-of-limitations purposes. Varden Cap. Props., LLC v.

Reese, 329 So. 3d 1230 (Ala. 2020). Rather, "[f]or statute-of-limitations

2The parties do not dispute that Moore's claims against Holland are

subject to the two-year limitations period. See Ala. Code 1975, § 6-2-38(l) (providing that "[a]ll actions for an injury to the person or rights of another not arising from contract and not specifically enumerated in this section shall be brought within two years"). 5 SC-2024-0345

purposes, the complaint must be filed and there must also exist 'a bona

fide intent to have it immediately served.' " Precise v. Edwards, 60 So. 3d

228, 231 (Ala. 2010) (quoting Dunnam v. Ovbiagele, 814 So. 2d 232, 237-

38 (Ala. 2001)). The question whether a bona fide intent existed at the

time the complaint was filed must be determined by an objective

standard. Varden, supra.

As previously indicated, the shooting incident occurred on

September 23, 2021; Moore commenced her action on March 22, 2022,

naming as defendants the City and fictitiously named parties. In June

2022, Moore learned through discovery that Holland and Gresham were

the officers involved in the shooting incident.

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Ex parte Robert Holland PETITION FOR WRIT OF MANDAMUS (In re: Ashley M. Moore v. City of Pleasant Grove) (Jefferson Circuit Court, Bessemer Division: CV-22-900141)., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ex-parte-robert-holland-petition-for-writ-of-mandamus-in-re-ashley-m-ala-2024.