Supreme Court of Alabama

Leanne W. Deaton v. South Highland Child Development Center, Inc., and Suzanne Snow. (Appeal from Jefferson Circuit…

June 7, 2024

Summary

The Supreme Court of Alabama affirmed dismissal of Deaton's claims against a day-care center and its executive director arising from their refusal to release her child to her despite her custodial order. The Court held that Deaton did not establish a duty owed to her, did not satisfy the requirements for res ipsa loquitur, and failed to plead facts supporting intentional infliction of emotional distress or intentional interference with parental rights. The Court also held that the trial court's dismissal and striking of the second amended complaint together constituted a final judgment and that the third amended complaint was barred by the trial court's prior ruling against amendment.