Altapointe Health Systems, Inc. v. Mobile County Probate Court

Summary

The Alabama Supreme Court held that a publicly funded mental-health organization may receive reasonable expert-witness fees when its qualified employees provide expert testimony in involuntary civil-commitment proceedings. The court interpreted Alabama Code § 22-52-14 according to its plain language, concluding that the statute does not exclude salaried employees or publicly funded organizations from eligibility. The court reversed the Mobile County Probate Court’s denial of fees and remanded for further proceedings.

Holdings

1. Section 22-52-14 authorizes payment from the state general fund of reasonable expert-witness fees when a qualified employee of Altapointe provides expert testimony in an involuntary civil-commitment hearing.
2. Once a qualified expert provides expert testimony within the scope of § 22-52-14, the probate court may determine the amount of a reasonable fee but may not categorically refuse payment based on the expert's employment relationship or public funding.

Questions Presented

1. Whether § 22-52-14, Ala. Code 1975, authorizes reasonable expert-witness fees when a publicly funded mental-health organization provides expert testimony through a qualified employee in an involuntary civil-commitment proceeding.
2. Whether the probate court may deny expert-witness fees because the expert is a salaried employee of the requesting organization or because the organization receives funding from other sources.

Disposition

reversed_and_remanded