Kennamer v. City of Guntersville, Alabama

Holding: The Eleventh Circuit affirmed the district court's dismissal of all claims, ruling that federal claims were time-barred and state law challenges were precluded by prior state court decisions.
Vote: Per Curiam opinion affirming the district court's dismissal.
Practical effect: The decision reinforces that federal courts must defer to state supreme court interpretations of state law and that Section nineteen eighty-three claims are subject to strict two-year statutes of limitations in the Eleventh Circuit.

The Eleventh Circuit affirmed the dismissal of a municipal taxpayer's federal and state law claims challenging land transactions by the City of Guntersville. The court held that the federal claims were time-barred and that the state law challenges were precluded by prior Alabama Supreme Court rulings.

Background

Joel Kennamer sued the City of Guntersville, Alabama, along with Mayor Leigh Dollar, Patrick Lawler, and related entities. He challenged the City’s 2019 lease and 2023 conveyance of land parcels to Mr. Lawler and his companies. The district court dismissed all claims under Rule twelve comma B comma six, and Kennamer appealed.

The court’s reasoning

The court first established that Kennamer had standing as a municipal taxpayer alleging misuse of funds. It then addressed the merits, rejecting arguments that the Alabama Supreme Court misinterpreted state law, noting that federal courts cannot question state court pronouncements on state law. The court held that federal claims were time-barred under the two-year statute of limitations for personal injury torts in Alabama. It also found no merit in arguments regarding unconstitutional ordinances, ultra vires claims, breach of trust, conspiracy under Section nineteen eighty-five, and due process violations, as the City was not required to hold a referendum under state law.

What it means going forward

The decision reinforces that federal courts must defer to state supreme court interpretations of state law and that Section nineteen eighty-three claims are subject to strict two-year statutes of limitations in the Eleventh Circuit.