Weekley v. U.S. Steel Mining Co.

Summary

The Alabama Supreme Court considers a petition for a writ of mandamus seeking dismissal of consolidated actions involving coal-dust emissions from a mining facility. The Court holds that the petition concerning the Weekley action is moot because the trial court lacked jurisdiction to reinstate that action after a post-judgment motion was denied by operation of law. It declines to dismiss the Waid action as a collateral attack on a prior class-action settlement because the Waid plaintiffs limited their claims to injuries occurring after the settlement's effective date.

Holdings

1. Because the Weekley plaintiffs' Rule 59(e) motion was deemed denied by operation of law after 90 days without express consent to extend the period, the trial court lacked jurisdiction to enter its later order purporting to vacate the dismissal and reinstate the Weekley action. The later order was void, and the mandamus petition concerning the Weekley action was moot.
2. The Waid action was not an impermissible collateral attack on the White class action because the Waid plaintiffs' claims were limited to alleged injuries occurring after the White settlement's effective date and therefore did not concern the settled claims subject to the White court's reserved jurisdiction.
3. A settlement release does not bar claims outside the scope of the matters specifically released; therefore, the White settlement did not preclude the Waid plaintiffs' claims based on injuries allegedly arising after the settlement's effective date.

Questions Presented

1. Whether the Supreme Court could grant mandamus concerning the Weekley action after the trial court's postjudgment motion had been denied by operation of law and the dismissal therefore remained effective.
2. Whether the Waid action was an impermissible collateral attack on the White class-action settlement and within the exclusive continuing jurisdiction reserved to the White class-action court.
3. Whether the White settlement and release barred claims for injuries allegedly occurring after the settlement's effective date.

Disposition

other