McCain v. Sneed and Smoot, [Ms. SC-2025-0130, Oct. 10, 2025] __ So. 3d __ (Ala. 2025). On ore tenus review, the Court (Lewis, J.; Stewart, C.J., and Wise, Sellers, and Cook, JJ., concur) affirms in part and reverses in part the Calhoun Circuit Court’s judgment entered following a bench trial in favor of James Sneed and Vernetta Smoot (“the lessees”) in a dispute involving a lease with option to purchase.
The Court rejects LaTonya McCain’s (“the lessor”) assertion that the circuit court erred in denying her claim that the lessees breached the lease/purchase agreement. The Court reiterates that “‘[a] party to a contract who has caused a failure of performance by the other party cannot take advantage of that failure.’” Ms. *13, quoting Big Thicket Broadcasting Co. of Alabama v. Santos, 594 So. 2d 1241, 1244 (Ala. Civ. App. 1991). The Court holds in light of “the evidence presented by the lessees, the trial court could have properly determined that the lessor had prevented the lessees’ performance of their November 2023 payment obligation in order to take advantage of the breach by canceling the lease.” Ibid.
Reiterating that option contracts are to be strictly construed, the Court reverses the circuit court’s order “crediting the monthly rent as a prepayment toward the purchase price.” Ms. *14, citing Colonial Baking Co. of Alabama v. Pine Dale, Inc., 436 So. 2d 856 (Ala. 1983). The Court concludes because “there is no ambiguity in the lease with respect to what payments are to be applied to the purchase price ... the trial court erred by holding that the monthly rent payments applied to the purchase price.” Ms. *15.