Wood v. Hayes
Annotate this CaseDarren Woods and his half sister Joni Wood, appealed a judgment based on a jury verdict in favor of Karrie Hayes and against Joni in the amount of $437,761.52 and against Darren in the amount of $86,540.49 for violating the Alabama Uniform Fraudulent Transfer Act ("AUFTA"). In 2004, Karrie Hayes, then age 14, was alone inside the house where she resided with her mother in Florence. Jason Earl Pruitt, at the request and under the direction of Stevie Woods, the father of Darren and Joni, released a large amount of propane gas into the residence and then ignited the gas, causing the residence to explode into flames. As a result of the explosion, Hayes sustained severe burns to over 70 percent of her body. Investigators quickly learned of Pruitt's involvement, and Pruitt thereafter implicated Stevie Woods. In 2006, Stevie Woods was arrested and charged with arson for the burning of the residence in which Hayes was living. Both Stevie Woods and Pruitt were convicted of arson in the first degree. Hayes, through her mother, filed a civil action against Stevie Woods and Pruitt seeking damages for the injuries she sustained as a result of the destruction of the residence. In amended complaints Hayes added claims alleging the fraudulent transfer of assets against Stevie Woods, Darren, Joni, and Flower Wood Development, LLC ("Flower Wood"), and conspiracy to engage in the fraudulent transfers and seeking injunctive relief to bar further transfers. With regard to these claims, Hayes specifically alleged that, with the knowledge of the existence of Hayes's claims against him, Stevie Woods fraudulently transferred real and personal property to various relatives, including Darren and Joni, as well as to Flower Wood. A jury awarded Hayes $5 million against Stevie Woods and Pruitt on her personal-injury claims. Stevie Woods did not appeal the verdict. The trial court determined that 11 deeds had been used to fraudulently transfer 9 parcels of real property from Stevie Woods to Darren, Joni, and Flower Wood, and the trial court set aside those deeds. The defendants did not challenge the order on appeal. Darren and Joni argued that the judgments based on the fraudulent transfers claims should be reversed on the ground that the trial court erred in admitting into evidence highly prejudicial photographs, medical records, and testimony concerning Hayes's injuries and photographs and testimony concerning the explosion. Upon review of this issue, the trial court's admission of evidence that was entirely irrelevant to Hayes's fraudulent-transfer claims and that was highly prejudicial to Darren and Joni. Therefore, the Supreme Court concluded that warranted reversal of the jury verdicts against Darren and Joni. Accordingly, the case was remanded for a new trial.
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