William Jenkins, as the personal representative of the Estate of Carl Grant v. City of Birmingham, Randall Woodfin, Scott Thurmond, Clinton Woods, Hunter Williams, Valerie Abbott, Jonathan T. Moore, Darrell O'Quinn, Crystal Smitherman, Wardine Alexander, Carol Clarke, Latanya Tate, and Vincent Larry (Appeal from Jefferson Circuit Court: CV-22-902083; Civil Appeals: CL-2024-0063).

CourtSupreme Court of Alabama
DecidedDecember 20, 2024
DocketSC-2024-0217
StatusPublished

This text of William Jenkins, as the personal representative of the Estate of Carl Grant v. City of Birmingham, Randall Woodfin, Scott Thurmond, Clinton Woods, Hunter Williams, Valerie Abbott, Jonathan T. Moore, Darrell O'Quinn, Crystal Smitherman, Wardine Alexander, Carol Clarke, Latanya Tate, and Vincent Larry (Appeal from Jefferson Circuit Court: CV-22-902083; Civil Appeals: CL-2024-0063). (William Jenkins, as the personal representative of the Estate of Carl Grant v. City of Birmingham, Randall Woodfin, Scott Thurmond, Clinton Woods, Hunter Williams, Valerie Abbott, Jonathan T. Moore, Darrell O'Quinn, Crystal Smitherman, Wardine Alexander, Carol Clarke, Latanya Tate, and Vincent Larry (Appeal from Jefferson Circuit Court: CV-22-902083; Civil Appeals: CL-2024-0063).) 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
William Jenkins, as the personal representative of the Estate of Carl Grant v. City of Birmingham, Randall Woodfin, Scott Thurmond, Clinton Woods, Hunter Williams, Valerie Abbott, Jonathan T. Moore, Darrell O'Quinn, Crystal Smitherman, Wardine Alexander, Carol Clarke, Latanya Tate, and Vincent Larry (Appeal from Jefferson Circuit Court: CV-22-902083; Civil Appeals: CL-2024-0063)., (Ala. 2024).

Opinion

Rel: December 20, 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

OCTOBER TERM, 2024-2025 _________________________

SC-2024-0217 _________________________

William Jenkins, as the personal representative of the Estate of Carl Grant, deceased

v.

City of Birmingham, Randall Woodfin, Scott Thurmond, Clinton Woods, Hunter Williams, Valerie Abbott, Jonathan T. Moore, Darrell O'Quinn, Crystal Smitherman, Wardine Alexander, Carol Clarke, Latanya Tate, and Vincent Larry

Appeal from Jefferson Circuit Court (CV-22-902083)

BRYAN, Justice.

William Jenkins, as the personal representative of the estate of

Carl Grant, deceased, appeals from a judgment of the Jefferson Circuit

Court ("the circuit court") entered in favor of Vincent Larry; the City of SC-2024-0217

Birmingham ("the City"); Randall Woodfin, the City's mayor; Scott

Thurmond, the City's chief of police; and city-council members Clinton

Woods, Hunter Williams, Valerie Abbott, Jonathan T. Moore, Darrel

O'Quinn, Crystal Smitherman, Wardine Alexander, Carol Clarke, and

Latanya Tate. Apart from Larry, all the appellees are hereinafter

collectively referred to as "the City defendants." For the reasons

explained below, we must dismiss this appeal.

Background

Jenkins's complaint in this action alleged the following. Grant, a

veteran of the Vietnam War, suffered from a range of health problems,

including dementia and post-traumatic stress disorder. Grant was a

resident of Conyers, Georgia, and, on February 2, 2020, he left his home

to go to the grocery store. Somehow, Grant ended up in Birmingham.

Larry, a police officer employed by the City, found Grant

disoriented and confused in a neighborhood. Larry detained Grant for a

misdemeanor offense and placed Grant in his patrol vehicle. Grant was

transported to the emergency room of a hospital. Hospital staff treated

Grant for minor skin abrasions on his face and began the process of

discharging him from care.

2 SC-2024-0217

Grant then asked to use the restroom, and Larry accompanied him.

Jenkins alleged:

"As Grant was walking to the restroom, he was[,] for unknown reasons[,] physically accosted and manhandled by Larry …. Apparently annoyed at the lack of comprehension from the clearly disoriented Grant, in the middle of the hospital hallway and in plain view of attending nurses, physicians, other staff, and video[-]surveillance equipment, Larry … violently picked Grant up and slammed him to the floor. … Upon impact with the floor, Grant's body immediately became limp."

Grant suffered injuries to his spinal cord. After undergoing emergency

surgery and months of treatment, Grant died on July 24, 2020.

Jenkins commenced this action on July 18, 2022, against Larry, the

City defendants, and fictitiously named defendants. Jenkins's complaint

asserted the following counts: (1) municipal liability, (2)

negligence/wantonness, (3) battery, (4) wrongful death, and (5) negligent

training/supervision. Jenkins sued all the named defendants in both

their official and individual capacities.

On August 17, 2022, the City defendants filed a motion to dismiss

or, in the alternative, a motion for a summary judgment. The City

defendants argued that Jenkins had failed to timely file a notice of his

claims in accordance with the requirements of §§ 11-47-23 and 11-47-192,

3 SC-2024-0217

Ala. Code 1975. The City defendants also argued that Jenkins's official-

capacity claims against them were barred by the doctrine of State

immunity. They further argued that Jenkins's individual-capacity

claims were due to be dismissed because those claims, the City

defendants argued, were substantively claims against the City that were

barred by the doctrine of State immunity.

The City defendants also asserted that Jenkins's claims against

Woodfin, Thurmond, and the members of the city council were barred by

the doctrines of supervisory immunity and State-agent immunity. The

motion contended that Jenkins's claims against Thurmond, the chief of

police for the City, should be dismissed because, the motion asserted,

Thurmond had begun serving as the chief of police two weeks after

Grant's death and Jenkins's allegations did not involve Thurmond.

Finally, the motion argued that an award of punitive damages against

the City was barred by § 6-11-26, Ala. Code 1975, and that Jenkins's

allegations against the individual City defendants were insufficient to

support a punitive-damages award under § 6-11-20, Ala. Code 1975. The

City defendants did not attach any evidence in support of their motion.

4 SC-2024-0217

Jenkins submitted a response to the City defendants' motion. On

November 7, 2022, Jenkins filed a motion for an entry of default against

Larry and requested a hearing to determine damages. Larry filed an

answer on January 9, 2023, and, later, a "motion to make moot" Jenkins's

motion for an entry of default against him. The circuit court entered an

order declaring Jenkins's motion for an entry of default to be moot. On

February 18, 2023, Jenkins filed an amended complaint, adding certain

allegations.

On February 22, 2023, the circuit court entered an order granting

the City defendants' motion to dismiss or, in the alternative, motion for

a summary judgment. In its order, the circuit court determined that

Jenkins had failed to comply with the requirements of §§ 11-47-23 and

11-47-192 in asserting his claims. The circuit court stated: "It is therefore

ORDERED, ADJUDGED and DECREED that the [d]efendants' [m]otion

for [a s]ummary [j]udgment is hereby GRANTED; and, any and all claims

asserted by [Jenkins] against the [d]efendants[] are hereby DISMISSED,

with prejudice." (Capitalization in original.)

The case-action summary in the State Judicial Information System

("SJIS") includes a February 23, 2023, entry stating: "CASE ASSIGNED

5 SC-2024-0217

STATUS OF: DISPOSED." (Capitalization in original.) Another entry

from that day states: "DISPOSED ON: 02/22/2023 BY (SUMMARY

JUDGMT)." (Capitalization in original.) The SJIS case-action summary

also includes a separate entry for each named defendant dated February

23, 2023, stating: "DISPOSED BY (SUMMARY JUDGMT) ON

02/22/2023." (Capitalization in original.)

On March 21, 2023, Jenkins filed a postjudgment motion to alter,

amend, or vacate the circuit court's February 22, 2023, order pursuant to

Rule 59(e), Ala. R. Civ. P. The motion also purported to seek relief under

Rule 60(b), Ala. R. Civ. P. Among other things, Jenkins asserted the

following in his motion:

"Per Alacourt, the Court's [o]rder dismissed all [d]efendants, including Vi[n]cent Larry, even though Larry did not file a motion for [a] summary judgment or [a] motion to dismiss and[,] in fact, Larry filed an [a]nswer on or about January 9, 2023.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Beatrice Silk v. Hilary Sandoval
435 F.2d 1266 (First Circuit, 1971)
Owens v. National SEC. of Alabama, Inc.
454 So. 2d 1387 (Supreme Court of Alabama, 1984)
Moore v. Prudential Residential Services
849 So. 2d 914 (Supreme Court of Alabama, 2002)
Baker v. Ball
473 So. 2d 1031 (Supreme Court of Alabama, 1985)
Ex Parte Davidson
782 So. 2d 237 (Supreme Court of Alabama, 2000)
Wise v. Watson
236 So. 2d 681 (Supreme Court of Alabama, 1970)
Roden v. Roden
937 So. 2d 83 (Court of Civil Appeals of Alabama, 2006)
Alabama Public Service Commission v. Redwing Carriers, Inc.
199 So. 2d 653 (Supreme Court of Alabama, 1967)
Howard v. McMillian
480 So. 2d 1251 (Court of Civil Appeals of Alabama, 1985)
Spina v. Causey
403 So. 2d 199 (Supreme Court of Alabama, 1981)
Johnson v. Harrison
130 So. 2d 35 (Supreme Court of Alabama, 1961)
Pierce v. Orr
540 So. 2d 1364 (Supreme Court of Alabama, 1989)
Thompson v. Keith
365 So. 2d 971 (Supreme Court of Alabama, 1978)
Cornelius v. Green
477 So. 2d 1363 (Supreme Court of Alabama, 1985)
Nowlin v. Druid City Hosp. Bd.
475 So. 2d 469 (Supreme Court of Alabama, 1985)
All American Life and Casualty Co. v. Dillard
255 So. 2d 17 (Supreme Court of Alabama, 1971)
City of Birmingham v. City of Fairfield
396 So. 2d 692 (Supreme Court of Alabama, 1981)
Ex Parte Johnson Land Co., Inc.
561 So. 2d 506 (Supreme Court of Alabama, 1990)
King Mines Resort, Inc. v. MALACHI M. & MINERALS, INC.
518 So. 2d 714 (Supreme Court of Alabama, 1987)
Washington v. Limerick
66 So. 3d 755 (Supreme Court of Alabama, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
William Jenkins, as the personal representative of the Estate of Carl Grant v. City of Birmingham, Randall Woodfin, Scott Thurmond, Clinton Woods, Hunter Williams, Valerie Abbott, Jonathan T. Moore, Darrell O'Quinn, Crystal Smitherman, Wardine Alexander, Carol Clarke, Latanya Tate, and Vincent Larry (Appeal from Jefferson Circuit Court: CV-22-902083; Civil Appeals: CL-2024-0063)., Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-jenkins-as-the-personal-representative-of-the-estate-of-carl-grant-ala-2024.