Code of Alabama

Ala. Code § 11-47-23 (2026)

Limitation Periods for Presentation of Claims Against Municipalities.

✓ official Alabama Legislature (ALISON) text, current July 2026
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All claims against the municipality (except bonds and interest coupons and claims for damages) shall be presented to the clerk for payment within two years from the accrual of said claim or shall be barred. Claims for damages growing out of torts shall be presented within six months from the accrual thereof or shall be barred.

(Code 1907, §1191; Code 1923, §1907; Code 1940, T. 37, §476.)

Notes of Decisions
Cited in 68 cases (14 in the last 5 years), 1981–2026 · leading case: Wheeler v. George, 39 So. 3d 1061 (Ala. 2009).
Wheeler v. George, 39 So. 3d 1061 (Ala. 2009). · cites it 15× “The City also argues that § 11-47-23, Ala.Code 1975, bars all claims against it.”
Miller v. City of Birmingham, 235 So. 3d 220 (Ala. 2017). · cites it 11× “Code 1975, and by § 11-47-23, Ala. Code 1975, the notice-of-claim statute for municipalities, (2) the City is immune from Mrs.”
Paul Boyle v. City of Pell City, 866 F.3d 1280 (11th Cir. 2017). · cites it 2× “The court further determined that Boyle’s state-law claims were barred under Alabama’s statutory notice requirement, Ala. Code § 11-47-23 . The City subsequently filed a motion for summary judgment, which the district court also granted.”
Harris v. City of Montgomery, 435 So. 2d 1207 (Ala. 1983). · cites it 6× “IV Plaintiffs assert that Code of Ala.1975, § 11-47-23, the municipal non-claim statute, does not apply to either the City or Officer Meads in this case, or alternatively that the statute was satisfied.”
Fomby v. City of Calera, 575 F. Supp. 221 (N.D. Ala. 1984). · cites it 13× “1983), which holds that Ala.Code § 11-47-23 (1975) is the most analogous and applicable statute of limitations which must be applied in actions brought against Alabama municipalities under 42 U.”
Howard v. City of Demopolis, 984 F. Supp. 2d 1245 (S.D. Ala. 2013). · cites it 4× “Specifically, she did not file a timely notice and a sworn statement with the City Clerk as required by Alabama Code § 11-47-23 and § 11-47-192. Ms.”
Babers v. City of Tallassee, Ala., 152 F. Supp. 2d 1298 (M.D. Ala. 2001). · cites it 2× “Defendants also assert that Plaintiffs state law claims must be dismissed because, inter alia, Plaintiff failed to file a notice of her potential claim against the City of Tallassee within six months from the date of the incident as is required by Ala.”
Patrick v. City of Florala, 793 F. Supp. 301 (M.D. Ala. 1992). · cites it 4× “See 1975 Code of Alabama §§ 11-47-23, 11-47-192. Section 11-47-23 establishes a six-month limitations period within which a claimant must notify the city clerk of a potential tort claim, while § 11-47-192 requires that a sworn statement describing the incident be filed with the…”
Oaks v. City of Fairhope, Ala., 515 F. Supp. 1004 (S.D. Ala. 1981). · cites it 2× “1975, § 11-47-23 (emphasis supplied). Although defamation is recognised as a tort in Alabama, United States Steel Corp.”
Shows v. Morgan, 40 F. Supp. 2d 1345 (M.D. Ala. 1999). · cites it 3× “See 1975 Code of Alabama §§ 11-47-23, 11-47-192 (1993).”
Davenport v. Neely, 7 F. Supp. 2d 1219 (M.D. Ala. 1998). · cites it 6× “Finally, Alabama Code § 11-47-23 provides a six month statute of limitations for suits against the City.”
City of Birmingham v. Davis, 613 So. 2d 1222 (Ala. 1993). · cites it 4× “" The City moved for a summary judgment on the grounds that the Davises had not filed a notice of claim with the City as required under § 11-47-23 and § 11-47-192, Ala.Code 1975.”
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