The City of Mountain Brook v. Rodney E. Miller and Mary Leah Miller

CourtSupreme Court of Alabama
DecidedJune 26, 2026
DocketSC-2025-0293
StatusPublished

This text of The City of Mountain Brook v. Rodney E. Miller and Mary Leah Miller (The City of Mountain Brook v. Rodney E. Miller and Mary Leah Miller) 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
The City of Mountain Brook v. Rodney E. Miller and Mary Leah Miller, (Ala. 2026).

Opinion

Rel: June 26, 2026

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 OCTOBER TERM, 2025-2026

_________________________

SC-2025-0293 _________________________

The City of Mountain Brook

v.

Rodney E. Miller and Mary Leah Miller

Appeal from Jefferson Circuit Court (CV-24-901073)

PER CURIAM.

On May 15, 2023, the home and property owned by the plaintiffs,

Rodney E. Miller and Mary Leah Miller, in Mountain Brook was flooded SC-2025-0293

with several feet of water, causing over $80,000 in damages. This was

only two weeks after they had purchased the property. According to the

Millers, the flooding occurred after stormwater overflowed through the

drain inlets in the City's drainpipes and released water onto their

property.

In March 2024, the Millers sued the City of Mountain Brook ("the

City") in the Jefferson Circuit Court. In their amended complaint filed

one month later, the Millers alleged claims of negligent maintenance,

trespass, and nuisance. Their allegations were based on the theory that,

despite being made aware of the flooding issues on their property and in

other areas and despite being made aware that its drainage system was

no longer adequate to handle the amount of stormwater that was being

drained through it, the City chose not to upgrade the drainage system.

This, they alleged, was a breach of the City's duty under Alabama law.

They thus sought injunctive relief and damages.

Following discovery, the Millers filed a motion for a partial

summary judgment, making these same arguments. In its response in

opposition to the Millers' motion, the City argued, among other things,

that it did not owe an individual duty to the Millers to upgrade its

2 SC-2025-0293

stormwater-drainage system because such services are public services

and any action taken related to that system necessarily implicates a duty

owed to the public at large. It also argued that Alabama law makes clear

that a municipality only owes a duty to an individual property owner not

to negligently design, construct, or maintain its stormwater-drainage

system so that it does not cause damage to that person's property.

Because the Millers failed to produce substantial evidence that there

were any maintenance issues with the City's drainpipes and drain inlets,

such as blockages, the City argued that the Millers were not entitled to

an offensive summary judgment in their favor and that it was, instead,

entitled to a summary judgment in its favor.

Following a hearing, the trial court granted the Millers' summary-

judgment motion. It also awarded them $80,441.15 in damages and

granted the Millers' request to permanently enjoin the City from further

flooding their property. It denied the City's motion for a summary

judgment.

The City now appeals. While our caselaw holds that Alabama law

authorizes a municipality to build a stormwater-drainage system, it also

recognizes that a municipality is not required to do so. If a municipality

3 SC-2025-0293

decides to take such action, it then owes a duty to individual landowners

not to design, construct, or maintain that system in a negligent manner.

In our view, a municipality's decision whether to upgrade its

stormwater-drainage system is due to be treated in the same manner as

its decision to build that system in the first place. Both decisions impact

the community, not just a single resident. Both decisions also involve

resolving competing wishes of different groups of constituents and

balancing large budget priorities. In short, both are questions for an

elected political body. The facts of this case amply demonstrate each of

these circumstances.

For the reasons stated below, we hold that the City did not owe an

individual duty to the Millers to upgrade its stormwater-drainage

system. We therefore reverse the trial court's summary judgment in favor

of the Millers and remand the case for that court to enter a summary

judgment in the City's favor on that basis.

Facts and Procedural History

The record indicates that the City's drainpipes have been in place

since at least 1928. Those pipes are part of a larger network of the City's

stormwater-drainage infrastructure in the area of Canterbury Road,

4 SC-2025-0293

Montevallo Road, Surrey Road, and Overhill Road located near Mountain

Brook Village. The Millers' property is located on Montevallo Road.

The City's drainpipes and drain inlets at issue here are part of a 12-

foot-wide stormwater-drainage easement (highlighted below) that runs

along the rear lot lines of the Millers' neighbors' properties (Lots 266,

267, 268, and 269) and the rear lot line of the Millers' property (Lot 265).1

1We note that the record does not contain an actual deed for the

easement; however, the parties do not dispute that the City had a dedicated "storm drain" easement here, and the record contains a copy of the subdivision plat for Mountain Brook Estates, which appears to constitute the deeding of the easement to the City. 5 SC-2025-0293

(Zoomed in.) Although there is no direct evidence of who placed the pipes

in the easement and no direct evidence of who owns the pipes in the

easement, both sides treat them as being owned by the City.2

Those pipes are connected to a separate 36-inch reinforce-concrete

pipe that traverses diagonally across the Millers' property (shown in

yellow below).3

2The City was incorporated in 1942. We assume that the county

owned the easements and the pipes before that and that they became the property of the City when it became incorporated. The parties do not argue otherwise.

3This image was presented to our Court by the Millers' counsel during oral argument on March 4, 2026, with no objection from the City. 6 SC-2025-0293

This pipe has drain inlets that receive stormwater from surrounding

properties and then channels that stormwater into the City's drainpipes.

I. The Engineering Studies Conducted on the City's Stormwater- Drainage System Near and Around the Millers' Property

It is undisputed that Montevallo Road, Canterbury Road, Surrey

Road, and Overhill Road have a long history of flooding. Over the years,

the City has hired different engineering firms to study the flooding in

those areas. Those studies revealed that the City's drainpipes and drain

inlets have become "undersized" because of the development throughout

the City over the years and, as a result, have a tendency to "surcharge"

during heavy rain events.

According to the record, "surcharging" occurs when the capacity of

a drainpipe is overloaded. Typically, the drain inlets capture the

stormwater and direct the stormwater underground to the City's

drainage system. However, when the drainpipes are overwhelmed, the

reverse occurs and water surcharges out of the drain inlets onto

surrounding properties, thus flooding those properties.

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