Ex parte Caremark Rx, LLC, 229 So. 3d 751

Background

In June 2000 the Franklin Circuit Court entered a final judgment approving a class-action settlement in Taff v. Caremark (Taff), and the court stated it "reserves and maintains continuing jurisdiction" over matters relating to the settlement.
In 1998–1999 MedPartners (Caremark predecessor) faced consolidated securities litigation that resulted in a global settlement; later litigation (Johnson) alleged fraud in that prior settlement and certified a class including TAPS purchasers.
The Jefferson Circuit Court preliminarily approved a $310 million settlement in Johnson (June 2016) requiring class members to file claims affirmatively; notice procedures were ordered and widely used.
Taff class counsel, seeking to notify Taff class members about potential claims in Johnson, moved the Franklin court (July 2016) to reopen Taff under Rule 60(b)(6) and to compel Caremark to produce a list of Taff class members and contact/trading information.
The Franklin court denied relief under Rule 60(b)(6) but—relying on its retained-jurisdiction language—ordered Caremark (Aug. 1, 2016) to produce identifying information; Caremark petitioned the Alabama Supreme Court for mandamus to vacate that order.
The Alabama Supreme Court granted mandamus, holding the Franklin court lacked jurisdiction to impose new disclosure obligations 16 years after the final judgment and outside the 30-day window to amend the judgment.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had jurisdiction 16 years after final judgment to order Caremark to produce class-member data	Taff: the court retained continuing jurisdiction per the June 2000 judgment; producing the list is ancillary to enforcing/implementing the settlement	Caremark: the court lost power to modify the judgment after 30 days; retained-jurisdiction language cannot extend jurisdiction indefinitely	Held: Trial court lacked jurisdiction; the order effectively modified the final judgment and was beyond residual enforcement authority
Whether Rule 60(b)(6) authorized reopening the judgment	Taff: initially invoked Rule 60(b)(6) to obtain relief for class members	Caremark: Rule 60(b) relief was inapplicable; no extraordinary circumstances shown	Held: Trial court denied Rule 60(b)(6) relief; court’s jurisdictional ruling made further Rule 60 analysis unnecessary
Whether a settlement judge may, post-judgment, require production of member lists absent prior contractual or rule-based obligation	Taff: needed the list to notify/assist class members to assert claims in Johnson	Caremark: never agreed to produce such a list; it does not possess all requested data; no settlement or rule required production	Held: No contractual or procedural basis existed to compel new disclosure; court could not impose new obligations now
Whether mandamus relief was appropriate to vacate the trial court order	Caremark: immediate review required because order exceeded jurisdiction and was burdensome	Taff: (implied) opposing relief to maintain access to member information	Held: Mandamus granted — Caremark had clear right and no adequate alternative remedy; trial court ordered to vacate its August 1 order

Key Cases Cited

Ex parte Integon Corp., 672 So.2d 497 (Ala. 1995) (standards for mandamus relief)
Pierce v. American Gen. Fin., Inc., 991 So.2d 212 (Ala. 2008) (trial court generally loses jurisdiction to amend a judgment 30 days after entry absent authorized motion)
George v. Sims, 888 So.2d 1224 (Ala. 2004) (trial court retains residual jurisdiction to enforce or interpret final judgments)
Schramm v. Spottswood, 109 So.3d 154 (Ala. 2012) (court cannot rely on broad retained-jurisdiction language to revisit a final judgment)
CVS Caremark Corp. v. Lauriello, 175 So.3d 596 (Ala. 2014) (background on related consolidated litigation and subsequent class-action proceedings)
State ex rel. Abdullah v. Roldan, 207 S.W.3d 642 (Mo. Ct. App. 2006) (trial court cannot retain jurisdiction beyond the rule-created postjudgment window to modify final decrees)
Ex parte Loube Consulting Int’l, Inc., 45 So.3d 741 (Ala. 2010) (mandamus review appropriate where production would be unduly burdensome)