Ex Parte Vulcan Materials Co.

992 So. 2d 1252, 2008 WL 1838309
CourtSupreme Court of Alabama
DecidedApril 25, 2008
Docket1051184
StatusPublished
Cited by19 cases

This text of 992 So. 2d 1252 (Ex Parte Vulcan Materials Co.) 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 Vulcan Materials Co., 992 So. 2d 1252, 2008 WL 1838309 (Ala. 2008).

Opinions

[EDITORS' NOTE: THIS PAGE CONTAINS HEADNOTES. HEADNOTES ARE NOT AN OFFICIAL PRODUCT OF THE COURT, THEREFORE THEY ARE NOT DISPLAYED.] *Page 1254

[EDITORS' NOTE: THIS PAGE CONTAINS HEADNOTES. HEADNOTES ARE NOT AN OFFICIAL PRODUCT OF THE COURT, THEREFORE THEY ARE NOT DISPLAYED.] *Page 1255

[EDITORS' NOTE: THIS PAGE CONTAINS HEADNOTES. HEADNOTES ARE NOT AN OFFICIAL PRODUCT OF THE COURT, THEREFORE THEY ARE NOT DISPLAYED.] *Page 1256

This petition for writ of mandamus seeks review of a trial court's order regarding permissible posttrial discovery in response to a motion for a remittitur of a punitive-damages award. We deny the petition in part and grant it in part.

I. Facts
James Blizard, doing business as Blizard Construction Company and Hollywood Materials (collectively referred to as "Blizard"), sued Vulcan Materials Company ("Vulcan") and Jeffrey Chandler. The trial court submitted the case to a jury on counts of breach of contract, various species of fraud, intentional interference with contractual or business relations, and civil conspiracy. The jury returned a verdict for Blizard on claims of breach of contract and intentional interference with business relations, awarding compensatory damages *Page 1257 of $130,000 and punitive damages of $3 million.2 According to the parties, the trial court entered judgment on the jury-verdict on February 1, 2006.

On March 1, 2006, Vulcan filed a "Renewed Motion for Judgment as a Matter of Law, or, in the Alternative, for New Trial, or, in the Further Alternative, for Remittitur and Constitutional Reduction of Punitive Damages." On March 9, 2006, Blizard served Vulcan with a postjudgment request for production of documents ("the request"). The request sought, in pertinent part:

"2. Any and all documents, including but not limited to, internal memoranda, press releases, notes, e-mail or correspondence circulated within Vulcan regarding this case and/or the verdict in this case.

". . . .

"8. Any and all balance sheets, income statements and/or financial statements generated by Vulcan for the past five (5) years.

"10. Any and all documents, including but not limited to memoranda, reports and/or correspondence, whether prepared by you, your agents, employees or attorneys, that were provided to independent auditors and/or consultants regarding any other litigation against Vulcan in preparation of the Financial Reports, Annual Reports, and/or other required reports relating to Vulcan's finances for the past five (5) years or since this case has been pending, whichever is greater.

"11. Federal corporate tax returns for Vulcan for the past five (5) years.

"12. State corporate tax returns for Vulcan for the past five (5) years.

"13. Audit reports prepared by Vulcan's independent auditors for the past five (5) years.

"14. All documents and/or working papers provided to you by your independent auditors which were used to determine `materiality' in the audited financial statements during the periods described above.

"19. Any and all copies of the Minutes of each meeting of the Vulcan Board of Directors or Trustees during the past five (5) years.

"21. Any and all reports and any and all statements which Vulcan has made to its stockholders within the past five (5) years.

"22. Copies of the complaints in each lawsuit filed within the last five years in which Vulcan is named as a defendant.

"24. Any and all documents, records, correspondence, e-mails, memos, statements, reports, papers or typed, printed or handwritten materials relating to the knowledge which Vulcan and/or its directors, managers or executive officers may have had during the past five (5) years with regard to verdicts and/or judgments rendered in the courts of Alabama during the past five (5) years.

"25. Any and all pleadings and/or documents that Vulcan has filed in other cases in the State of Alabama in which the excessiveness of punitive damages was challenged.

*Page 1258
"26. A copy of all pleadings or documents that Vulcan has filed (or someone has filed on its behalf) in the state of Alabama or any other state in which it argued (even indirectly) it was entitled to punitive damages.

"27. An itemization of the fees and expenses paid to any attorney for the defense of this case.

"35. Please supplement with updated information all your previous responses to requests for production."

Blizard also served Vulcan with post-judgment interrogatories ("the interrogatories"). The interrogatories stated, in pertinent part:

"20. State whether or not there have been, or are now, lawsuits pending against Vulcan claiming injury or damage from wrongful interference with business or contractual relations, improper restraint of trade, and/or improper price fixing. If so, for each lawsuit state:

"(a) the date of the filing of each such lawsuit;

"(b) the court in which such lawsuit was filed;

"(c) the nature of each such lawsuit; "(d) the names and addresses of all parties, including plaintiffs and defendants to each such lawsuit;

"(e) a full and complete statement of the substance of all claims and allegations of each such suit;

"(f) the jurisdiction in which each such action was filed;

"(g) the jurisdiction in which each such action came or will come to trial if different from answer in (f);

"(h) the disposition of each such lawsuit; and

"(i) the name and address of each person or entity having possession, control or custody of any or all records relating to such legal action against this defendant involving such a claim or similar claim.

"23. Please state the total amount of attorney's fees and expenses reimbursed and/or paid to your attorneys in this case. . . .

"24. Has Vulcan ever acquired rights in property which included an existing rock quarry and that another entity was operating (e.g., selling ag lime, producing rock for sale, etc.) in at the time of said acquisition? If so, please identify all such quarries and provide the name, address, and telephone number of each entity working in that quarry at the time of Vulcan's acquisition."

On April 10, 2006, Vulcan filed responses to the request and interrogatories, objecting to these discovery requests on grounds of relevance, overbreadth, undue burden, and attorney-client privilege. In particular, Vulcan objected to producing discovery of its financial wealth and condition, stating that such discovery was irrelevant because Vulcan was "expressly disclaim[ing]" reliance on its financial position as a reason for remitting the punitive damages awarded by the jury.

On April 19, 2006, Blizard filed a motion to compel Vulcan to respond to the posttrial discovery. On April 26, 2006, the trial court held a hearing on the motion to compel. Subsequently, on May 8, 2006, the trial court issued an order compelling Vulcan to respond within 21 days to the request and the interrogatories.

Eleven days later, on May 19, 2006, Vulcan filed a motion for a protective order and a conditional motion for a stay of all postjudgment discovery pending this Court's review of its petition for the writ of *Page 1259 mandamus. In that motion, Vulcan stated that it had "already produced or [would] produce" documents sought in request no. 25, but limited to the last five years, and documents sought in request no.

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Ex Parte Vulcan Materials Co.
992 So. 2d 1252 (Supreme Court of Alabama, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
992 So. 2d 1252, 2008 WL 1838309, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ex-parte-vulcan-materials-co-ala-2008.