LeBlanc v. Residence Doctor Home Inspection, LLC, et al.,[Ms. SC-2023-0843, Nov. 15, 2024] __ So. 3d __ (Ala. 2024). The Court (Stewart, J.; Parker, C.J., and Bryan, Sellers, and Cook, JJ., concur; Wise, J., recuses) affirms a summary judgment entered by the St. Clair Circuit Court dismissing Hudgen and Jodi LeBlanc’s claims against Residence Doctor Home Inspection, LLC (“the inspection company”), and Terry J. Holder, the owner-operator of the inspection company, arising from a home inspection Holder performed. The gravamen of the LeBlancs’ claims was that “Holder’s inspection report did not inform them of any structural issues with the flooring of the home but, rather, informed them only that Holder had found ‘microbial growth’ on the floor joists in the crawl space and that they should hire a mold remediation specialist to further inspect and remove the microbial growth.” Ms. *2.
The Court concludes expert testimony was required because “[h]ome inspectors, like real-estate appraisers, are also required to be licensed, engage in a profession requiring specialized knowledge, and their profession is regulated by the State; thus, they qualify as professionals. See Ala. Admin. Code (State Dep’t of Fin.), Chapters 355-17-1 and 355-18-1. Accordingly, as in Riverstone [Dev. Co. v. Garrett & Assocs. Appraisals, Inc., 195 So. 3d 251 (Ala. 2015) (plurality opinion)], the LeBlancs were required to present expert testimony to establish the applicable standard of care and Holder’s breach of that standard of care.” Ms. *10.