Riley v. Pate

Summary

The Supreme Court of Alabama held that Luther S. Pate lacked standing, either as a taxpayer or as a beneficiary, to challenge the allocation of interest from an Exxon Mobil judgment between the Alabama Trust Fund and the state general fund. Because the trial court lacked subject-matter jurisdiction, the court vacated the preliminary injunction, dismissed the action, and dismissed the appeal. A special concurrence discussed possible settlor standing and the failure to name all indispensable trustees.

Holdings

1. Pate lacked taxpayer standing because the Alabama Trust Fund receives no tax revenue and taxpayers were not liable to replenish any shortfall in the Fund.
2. Pate lacked beneficiary standing because his interest as an Alabama citizen was no greater than the interest of the large class of citizens who might benefit from Trust Fund expenditures, and he alleged no actual or imminent, particularized, concrete, and palpable injury or sufficient special interest in enforcement of the trust.
3. When a party without standing commences an action, the trial court acquires no subject-matter jurisdiction; orders entered without subject-matter jurisdiction are void and cannot support an appeal.

Questions Presented

1. Whether Pate had taxpayer standing to challenge the officials' deposit of interest from the Exxon judgment into the general fund.
2. Whether Pate had standing as an intended beneficiary or potential beneficiary of the Alabama Trust Fund.
3. Whether the circuit court's preliminary injunction could support an appeal when the action was initiated by a party lacking standing and therefore subject-matter jurisdiction.

Disposition

other