City of Gadsden v. Boman, 143 So. 3d 695

John Boman, a former Gadsden police officer, retired in 1991 under a handbook-backed retirement program that promised lifetime medical care.
Gadsden later joined the State Employees’ Insurance Board’s Local Government Health Insurance Plan, with Blue Cross as claims administrator; the State plan states Medicare becomes primary when entitlement occurs.
Boman turned 65 in 2011; after that, Blue Cross denied claims for lack of Medicare record, though Boman alleges he never received Medicare coverage or credits.
Boman sued Gadsden and later added Board members and the State plan as defendants, seeking injunctive relief and a declaration of primary medical coverage.
The circuit court granted emergency and summary relief in 2011–2013, holding Boman not Medicare-entitled, ordering Board members to provide primary care, and ordering Gadsden to cover gaps; the orders were appealed.
This Court reversed, holding that the Board’s interpretation of the State plan should be adjudicated and that Boman’s entitlement to Medicare for primary coverage was mischaracterized; the case was remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the circuit court properly issued injunctive relief against Board members	Boman claims Board officials must provide primary coverage under the State plan.	Board asserts immunity and that Medicare entitlement controls primary/secondary status.	Reversed: injunctive relief against Board members improper; remand.
Whether Boman was entitled to primary State plan coverage by Medicare entitlement	State plan should provide primary coverage because Boman is not Medicare-eligible.	Once entitled to Medicare, State plan becomes secondary; Boman is Medicare-entitled.	Reversed: Boman not entitled to Medicare under plan; primary coverage not established.
Whether injunctions against Gadsden were proper	Gadsden must provide continued medical benefits per retirement program.	No final merits hearing; security requirements and lack of final judgment foreclose permanent injunction.	Reversed: preliminary injunction against Gadsden improper; remand.
Whether the January–February 2013 orders complied with Rule 65(c) security and stayed standards	Orders issued without security were proper due to overriding public concern.	Rule 65(c) requires security and explicit exceptions; court failed to apply them.	Reversed: security and exceptions not demonstrated; injunctions improper.

Dawkins v. Walker, 794 So.2d 333 (Ala. 2001) (appeal from injunctive-relief order treated as such; injunctive relief appealable)
Spinks v. Automation Personnel Services, Inc., 49 So.3d 186 (Ala. 2010) (Rule 65(c) security required for preliminary injunction; bond must be posted)
Shoney’s LLC v. MAC E., LLC, 27 So.3d 1216 (Ala. 2009) (contract interpretation: ordinary meaning when unambiguous)
Homes of Legend, Inc. v. McCollough, 776 So.2d 741 (Ala. 2000) (contract interpretation: enforce plain terms when unambiguous)
Walden v. ES Capital, LLC, 89 So.3d 90 (Ala. 2011) (permanent injunction standards and de novo review)
TFT, Inc. v. Warning Sys., Inc., 751 So.2d 1238 (Ala. 1999) (permanent injunction standards; de novo review clarified)