County personnel board brought action against city, seeking declaration that act allowing certain municipalities to remove themselves from jurisdiction of their county’s personnel board violated Alabama Constitution’s provisions on special and local laws and that city’s subsequent departure from board’s jurisdiction pursuant to that act was void.
In response to motion by city, the Circuit Court dismissed action with prejudice. Board appealed.
The Supreme Court held that:
- Board was within group affected by act, as required for board to have standing to challenge act’s constitutionality pursuant to test for standing as articulated in Express Enterprise, Inc. v. Waites, 979 So.2d 754;
- Board’s loss of jurisdiction constituted injury-in-fact under the traditional and default test for standing in public-law actions;
- Board’s imminent loss of $300,000 if city were allowed to depart from board’s jurisdiction under act constituted injury-in-fact under the traditional and default test for standing in public-law actions;
- Board’s injury-in-fact had direct causal link to act’s passage;
- Board’s injury-in-fact was redressable by a favorable court decision; and
- If it turned out to be true that city was the only municipality in the State that met act’s requirements, then Legislature, before act’s enactment, had to comply with Alabama Constitution’s notice requirements for special and local laws.