IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA BIRMINGHAM DIVISION

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1 ELECTRONICALLY FILED 5/18/2012 2:30 PM CV CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA ANNE-MARIE ADAMS, CLERK IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA BIRMINGHAM DIVISION ZACHARY SPITZER, ) ) Plaintiffs, ) ) v. ) Civil Action No.: ) E. CLAYTON LOWE, JR.; LOWE & ) GRAMMAS, LLP; WILSON F. ) GREEN; FLEENOR & GREEN, LLP, ) DONALD R. JONES, JR.; DONALD R. ) JONES, JR., P.C.; ) ) Defendants. ) Jurisdiction and Venue COMPLAINT Zachary Spitzer, Plaintiff in this action, represents as follows: 1. Plaintiff, Zachary Spitzer, is an individual living in Jefferson County, Alabama, and is over the age of 21 years, and paid occupational taxes to Jefferson County from January 1, 2010 through April 20, Plaintiff has not received a refund of said taxes. 2. Defendant E. Clayton Lowe ( Lowe ) is a lawyer who at all times relevant hereto was licensed to practice law in Alabama, with his principal place of business in Birmingham, Alabama, and is a shareholder of Lowe & Grammas, LLP. 3. Defendant Lowe & Grammas, LLP ( L&G ), is, upon information and belief, an Alabama limited liability partnership with offices in Jefferson County, and which does business in Jefferson County, Alabama. At all times referred to herein, Defendant Lowe was acting as its agent and one of its principals. 1

2 4. Defendant Wilson F. Green ( Green ) is a lawyer who at all times relevant hereto was licensed to practice law in Alabama, with his principal place of business in Tuscaloosa, Alabama, and is a shareholder in Fleenor & Green, LLP. 5. Defendant Donald R. Jones, Jr. ( Jones ) is a lawyer who at all times relevant hereto was licensed to practice law in Alabama, with his principal place of business in Montgomery, Alabama, and is a shareholder in Donald R. Jones, Jr., P.C. 6. Defendant Donald R. Jones, Jr., P.C. ( DRJ, PC ) is, upon information and belief, an Alabama law firm operating as a professional corporation with offices in Montgomery, Alabama, and which does business in Jefferson County, Alabama. At all times referred to herein, Defendant Jones was acting as its agent and one of its principals. 7. Defendant Fleenor & Green, LLP ( F&G ), is, upon information and belief, an Alabama law firm operating as a limited liability partnership with offices in Tuscaloosa County, and which does business in Jefferson County, Alabama. At all times referred to herein, Defendant Green was acting as its agent and one of its principals. 8. Venue of this Honorable Court is predicated upon these Defendants and their representation of Plaintiff, and all others similarly situated, entering into a contract for legal representation in Jefferson County, Alabama, for the rendering of services in this County. 9. The amount in controversy exceeds the minimal jurisdictional requirements of this Honorable Court. Facts 10. F&G, L&G, and DRJ, PC, with Messrs. Green, Lowe and Jones as responsible attorneys, were engaged by Jeffrey Weissman, DDS, and Keith Shannon to represent themselves and a class of persons similarly situated with regard to claims brought against Jefferson County 2

3 arising out of the adoption, on or about August 14, 2009, of Alabama Act , which purported to allow Jefferson County to impose and collect an occupational tax from workers and a business license tax from the worker s employers. Weissman and Shannon, and the class they sought to represent, alleged that 2009-Act 811 was unconstitutional and void insofar as it purported to confer enabling authority on Jefferson County to impose occupational taxes on the plaintiffs, such that Weissman and Shannon, and those similarly situated, were due a refund of such taxes. Weissman and Shannon filed their action on December 16, Weissman and Shannon also alleged that any business license tax imposed by Act was also void and unconstitutional. The lawsuit filed by Weissman and Shannon was ultimately certified as a class action, with one class designated as the New Act Class composed of all workers who paid the occupational tax. In addition to the New Act Class, a Business License Sub-Class was certified consisting of all businesses that paid a business license tax under Jefferson County Ordinance 1791 or In short, Plaintiff, and the class he seeks to represent, were and are members of the New Act Class. The employers of the New Act Class were and are, upon information and belief, members of the Business License Sub-Class. 11. On December 1, 2010, Judge Charles Price, sitting as a Jefferson County Circuit Judge, entered a Final Order agreeing with the Weissman and Shannon Plaintiffs that Act was unconstitutional because the published notice of the act did not comply with Article IV, Section 106 of the Alabama Constitutional and applicable case law. Additionally, the Court found that the plaintiffs were entitled to summary judgment on their claim to enjoin Jefferson County from imposing or collecting any and all occupational or business license taxes imposed under the ordinance Jefferson County passed in reliance on Act , but, ultimately, 3

4 Jefferson County was allowed to continue to collect the occupational taxes from class members working in Jefferson County pending the resolution of the appeal filed by Jefferson County. The amount collected during the pendency of the appeal totaled, approximately, $26,000, In his December 1, 2010 ruling, Judge Price refused to make his findings retroactive: He made the relief prospective only. The prospective-only relief awarded was challenged on appeal by Weissman and Shannon on behalf of the class. Should the appeal be successful, substantial more money will be due to be refunded to the members of the New Act Class a/k/a the members of the class in this matter. 13 After securing the summary judgment, and prevailing on the appeal taken by the County, class counsel, and all named Defendants, had a duty to ensure the return of occupational tax dollars to Plaintiff and others similarly situated. Defendants breached this duty by allowing, without even an objection, the money owed to the tax payors (AKA the New Act Class) to be paid, instead, to the tax payors employers (the members of the Business License Sub-Class). 14. This breach occurred because the method adopted by class counsel and the administrator was woefully inadequate. The method consisted of a single letter issued by the administrator to the employers, which simply said: Attached is a check from the Jefferson County Occupational Tax Distribution Fund representing a refund of Taxes paid to Jefferson County for your December 2010 and January 2011 tax obligation. The enclosed check represents your pro rata share of all taxes collected and held in escrow by Jefferson County during this time period less attorneys fees, class representative incentive awards, and administrative expenses, all as awarded by the Court. Any uncashed check received by the Administrator from Jefferson County was returned by prior correspondence. You should consult your tax professional regarding the impact of this distribution on your income tax liability. (See attached Exhibit A.) 4

5 15. The method of returning the tax dollars to the class members was not made the subject of any hearing, nor was notice issued with regard to this method of return. 16. The correspondence issued by the administrator makes no mention of the fact that the great majority of the dollars represented in any such check should be returned to the employer s employees. Indeed, there is not even a suggestion of such in the letter as the letter plainly states that the funds conveyed to the recipient of the letter were your pro rata share less attorneys fees, class representative incentive awards, and administrative expenses, all as awarded by the Court. (emphasis added). 17. Because Defendants F&G, L&G, DRJ, PC, Green, Lowe and Jones acted as class counsel for both the New Act Class (ie: the workers who paid the occupational taxes and the putative Plaintiff class in this matter) and the Business License Sub-Class, the likely employers of the New Act Class, the decision to pay refunds owed to Plaintiff and others similarly situated to their putative employers created a conflict of interest. Based on the wording of the letter issued and the failure to provide members of the class with individual refund, there is an inescapable conflict of interest created by issuing checks to employers only. The employers were likely to believe that the check was a refund of their business license fees rather than a refund of occupational taxes paid by their employees the Plaintiff Class. Such mistaken belief is furthered by the wording of the letter issued over Mr. Penton s signature that the enclosed check represents your pro rata share of all taxes collected, and that you should consult your tax professional regarding the impact of this distribution on your income tax liability. Not only is there no mention that a majority of these dollars belong to the employees, there is affirmative indication that all of the dollars belong to the employer. 5

6 18. Class counsel were awarded $6.4 million in fees, despite this defective distribution methodology. The fees awarded the class counsel by the Court were sought in a 29- page motion filed on April 5, 2011 at 2:49 p.m. The trial court, in a 16- page opinion, granted the fee petition awarding the entire $6.4 million to plaintiff s counsel at 4:53 p.m. the same day. Clearly, no notice or hearing was afforded the Plaintiff or the Class as to the fees. Said fees are excessive, given the methodology adopted by class counsel for the distribution of the tax refund was not reasonably designed to return the funds to the Plaintiff Class. Class Allegations 19. In addition to bringing this action on his/her behalf, Plaintiff also brings this action as the representative of the Class, which is defined as all individuals or entities that paid occupational taxes collected by Jefferson County as further described above, but have not received the refunds owed. The Class does not include Defendants, their agents, employees, representatives or legal counsel. 20. Numerosity (Ala. R. Civ. P. 23(a)(1)): The members of the Class are so numerous and geographically dispersed that joinder of all members is impracticable. On information and belief, Plaintiff alleges that there are thousands of members of the Class in Jefferson County and the rest of Alabama. 21. Commonality (Ala. R. Civ. P. 23(a)(2)): Common questions of law and fact exist as to all members of the Class. These commons questions include, but are not limited to: a. Whether Defendants methodology for returning the occupational tax refund occupational tax payors was reasonable; b. Whether Defendants wrongfully, negligently, and/or willfully failed to ensure the return of occupational tax refunds to Plaintiff and others similarly situated 6

7 individuals; c. Whether Defendants must pay and/or reimburse Plaintiff and members of the Class all such amounts imposed, collected, and received by Defendants and distributed by the Defendants to non-party employers with no direction to pay over the monies to their rightful owners the employees. 22. Typicality (Ala. R. Civ. P. 23(a)(3)): Plaintiff's claims are typical of the claims of absent members of the Class. 23. Adequacy of Representation (Ala. R. Civ. P. 23(a)(4)): The named Plaintiff will fairly and adequately represent and protect the interests of the Class. Plaintiff has no interests that are antagonistic to the absent class members. Plaintiff is represented by capable counsel. 24. Rule 23(b)(1)(A) Class: Class certification is appropriate under Ala. R. Civ. P. 23(b)(1)(A) because the prosecution of separate actions by individual members of the Class would create a risk of inconsistent or varying adjudications with respect to individual members of the class which would establish incompatible standards of conduct for Defendants. 25. Rule 23(b)(2) Class: Class certification is also appropriate under Ala. R. Civ. P. 23(b)(2) with respect to Plaintiff s demands for injunctive and declaratory relief against Defendants because Defendants have acted on grounds generally applicable to the Class as a whole. For instance, Defendants developed a method to return to the employees their improperly collected monies and funds based on the taxes and/or fees allegedly authorized by Act and Jefferson County Ordinance 1791 or An adjudication that the methodology adopted by the Defendants is unreasonable and in violation of the law, and that Plaintiff and the Class are entitled to a refund of those amounts paid over to the employers will apply to and affect Plaintiff and members of the Class in the same way. The reverse is true as well. 7

8 26. Rule 23(b)(3) Class: Class certification is also appropriate under Alabama Rules of Civil Procedure 23(b)(3) because common questions of law and fact predominate over questions affecting only individual members. Moreover, a class action is superior to any other method for fair and efficient adjudication of the controversy. Plaintiff also avers that this action is manageable as a class action. COUNT ONE Negligence and Wantonness 27. Plaintiff adopts and realleges paragraphs 1 through 26 as if fully set out herein. 28. Plaintiff, on behalf of himself and the class he seeks to represent, specifically alleges, under the Alabama Legal Services Liability Act, that the Defendants negligently and/or recklessly or wantonly failed to exercise the same degree of care, skill and diligence as a reasonably prudent attorney would have exercised under the same or similar circumstances in that the Defendants: a. Failed to properly develop an appropriate methodology to return the occupational tax dollars to the true payors of those dollars the employees; and failed to object to the faulty method adopted by the Court; b. Failed to advise the occupational tax payors that there was a conflict between the interests of the occupational tax payors and the payors of the business license fees under the distribution system put in place by Defendants; c. Failed to assure that the plaintiffs were afforded a meaningful hearing with an opportunity to be heard on this distribution method; 8

9 d. Failed to provide notice to the plaintiff and those who paid the occupational tax with regard to the methodology accepted by class counsel to distribute the monies; e. Failed to properly and professionally perform their duties as class counsel in this matter. 29. As a direct and proximate consequence of said negligence and/or wantonness, the plaintiff and class has been caused to suffer monetary damages in that the tax refund was not provided. WHEREFORE, plaintiff, and the class, demands judgment against Defendants for such compensatory damages and punitive damages as the jury shall award, plus interest, costs, and attorneys fees. COUNT TWO Breach of Contract 30. Plaintiff adopts and realleges paragraphs 1 through 29 as if fully set out herein. 31. Plaintiff, on behalf of himself and a class of others similarly situated, avers that, under the Alabama Legal Services Liability Act, Defendants breached their contract of employment with the Plaintiff and the class in that the Defendants failed to exercise the same degree of care that a reasonably prudent attorney would have exercised under the same or similar circumstances as more fully set forth above. 32. As a direct and proximate consequence of the Defendants breach of contract, the Plaintiff and class have been caused to suffer monetary damages as outlined above. 9

10 WHEREFORE, Plaintiff, and class, demands judgment against Defendants for such compensatory damages and punitive damages as the jury shall award, plus interest, costs, and attorneys fees. COUNT THREE Breach of Fiduciary Duty 33. Plaintiff adopts and realleges paragraphs 1 through 32 as if fully set out herein. 34. Plaintiff, on behalf of himself and a class of others similarly situated, alleges that as a result of the attorney/client relationship between the Defendants and the Plaintiff Class, the Defendants were in a fiduciary relationship with the Plaintiff Class. Indeed, Plaintiff alleges that because of the class action nature of this litigation, that fiduciary relationship is a particularly salient one. Plaintiff alleges that under the Alabama Legal Services Liability Act, the Defendants breached the said fiduciary duty in that Defendants failed to exercise that same degree of care that a reasonably prudent attorney would have exercised under the same or similar circumstances as more fully set forth above. WHEREFORE, Plaintiff demands judgment against Defendants for such compensatory damages and punitive damages as a jury shall award, plus interest, costs, and attorneys fees. COUNT FOUR Suppression of Material Fact 35. Plaintiff adopts and realleges paragraphs 1 through 34 as if fully set out herein. 36. Plaintiff, on behalf of himself and a class of others similarly situated, avers that under the Alabama Legal Services Liability Act, during the Defendants representation of the Plaintiff Class, Defendants failed to exercise the same degree of care that a reasonably prudent attorney would have exercised under the same or similar circumstances, in that the Defendants 10

11 suppressed material facts they were under obligation to communicate to the Plaintiff Class. Said obligation to communicate arose from the confidential relationship of the parties as attorney and client. Plaintiff Class avers that the material facts that the Defendants suppressed were, among others, those set forth above. 37. As a direct and proximate consequence of said suppression of material facts, Plaintiff Class has been caused to suffer monetary damages as outlined above. WHEREFORE, Plaintiff, and the class,demands judgment against Defendants for such compensatory damages and punitive damages as a jury shall award, plus interest, costs, and attorneys fees. COUNT FIVE Injunctive Relief 38. Plaintiff Class adopts and realleges paragraphs 1 through 37 as if fully set out herein. 39. The Plaintiff Class and the absent class members have been and continue to be injured by the efforts of the Defendants to distribute the tax refunds under an unreasonable methodology. 40. The Defendants knowingly gave the funds of the Plaintiff Class to third parties with the mere hope that those third parties will properly disburse the money to the Plaintiff Class. Because of the pendency of the appeal described, supra, the flawed distribution method could be employed yet again. 41. The Defendants have not refrained from committing the above-described acts, and Defendants have refused to stop their illicit actions and continue to commit the illicit practices hereinabove described. 11

12 42. As a result of the Defendants actions, the Plaintiff and the members of the putative class have sustained and will continue to sustain irreparable injury. 43. The Plaintiff cannot be fully compensated in damages, and is without adequate remedy at law because the exact amount of damages that Plaintiff will sustain will be difficult to determine and absent an injunctive relief order by this Court, the Defendants practices will continue in place, unabated. WHEREFORE, Plaintiff and absent class members pray that upon a final hearing and determination of this cause, the Court will enjoin the Defendants from continuing the wrongful act herein complained of. The Plaintiff further prays for compensatory damages as may be allowed by law, plus interest, and other injunctive relief as may be appropriate under Alabama law and as determined by the Court. /s/ James W. Woolley JAMES W. WOOLLEY (WOO-081) ATTORNEY FOR PLAINTIFF Woolley Law Firm, LLC st Avenue North Suite 450, The McAdory Building Birmingham, Alabama 3520 (205) Facsimile: (205)

13 PLEASE SERVE DEFENDANTS AS FOLLOWS: E. Clayton Lowe, Jr. LOWE & GRAMMAS, LLP 1952 Urban Center Parkway Vestavia Hills, AL LOWE & GRAMMAS, LLP c/o E. C. Lowe, Jr., Registered Agent 1952 Urban Center Parkway Vestavia Hills, AL Wilson F. Green FLEENOR & GREEN, LLP 204 Marina Drive, Suite 200 Tuscaloosa, AL FLEENOR & GREEN, LLP c/o Wilson F. Green, Registered Agent 204 Marina Drive, Suite 200 Tuscaloosa, AL Donald R. Jones, Jr. DONALD R. JONES, JR., P.C. Suite Interstate Park Drive Montgomery, AL DONALD R. JONES, JR., P.C. c/o Donald R. Jones, Jr., Registered Agent Suite Interstate Park Drive Montgomery, AL

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