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Maddox v. Madison County Com'n
Citations: 661 So. 2d 224; 1995 Ala. LEXIS 209; 1995 WL 259962Docket: 1931432
Court: Supreme Court of Alabama; May 5, 1995; Alabama; State Supreme Court
The Supreme Court of Alabama affirmed the Madison County Commission's unanimous decision to deny Royce Lane Maddox's application for an off-premises retail liquor license for his business, Doyce's Spirits. Maddox filed his application with the Alabama Alcoholic Beverage Control Board on March 2, 1992, but needed county commission approval due to the location of his business in an unincorporated area. The county commission held a public hearing on December 6, 1993, before voting to deny the application based on a resolution that required liquor licenses to be located in predominantly commercial areas. Maddox subsequently filed a petition for judicial review, but the trial court upheld the commission's decision after an ore tenus trial, presuming the correctness of the trial court's findings unless shown to be plainly wrong. Maddox's arguments regarding the constitutionality of the commission's resolution and procedures were deemed waived because he did not raise them in his appellate brief. Maddox argues that the county commission's denial of his liquor license application was arbitrary and capricious due to a lack of supporting evidence, claiming the trial court's judgment was palpably erroneous. However, under Alabama law, the applicant bears the burden of proving the commission's actions were arbitrary and capricious for a reversal. During the December 6, 1993 hearing, Maddox did not testify or present evidence, while opposition was voiced by an attorney representing local residents and 17 residents who cited concerns about traffic safety and the area being non-commercial. The commission denied the application, citing that Doyce's was not located in a commercial area. Testimony revealed that Doyce's is situated on a rural road, near a restaurant that does not serve liquor and with limited commercial activity nearby. Residents live close to the property, and the Madison County administrator and a county commissioner both characterized the area as rural or residential, despite the presence of a restaurant. A March 1992 ABC Board report classified the area as "rural residential." The court determined that the commission's decision was not arbitrary and capricious, supported by sufficient reasons for denial, and thus upheld the trial court's judgment. The judgment is affirmed.