Code of Alabama
Ala. Code § 6-2-37 (2026)
Commencement of Actions - Three Years.
✓ official Alabama Legislature (ALISON) text, current July 2026
The following must be commenced within three years:
(1) Actions to recover money due by open or unliquidated account, the time to be computed from the date of the last item of the account or from the time when, by contract or usage, the account is due; and
(2) Proceedings in any court of this state to disbar any attorney authorized to practice law in this state.
(Code 1852, §2480; Code 1867, §2904; Code 1876, §3229; Code 1886, §2618; Code 1896, §2799; Code 1907, §4838; Acts 1915, No. 814, p. 928; Code 1923, §8947; Code 1940, T. 7, §24.)
Notes of Decisions
Cited in 23
cases (5 in the last 5 years), 1982–2023 · leading case: In re Templeton, 538 B.R. 578 (Bankr. N.D. Ala. 2015).
In re Templeton, 538 B.R. 578 (Bankr. N.D. Ala. 2015). “For one particular subset of claims, those representing medical debts incurred more than three but less than six years before the petition dates, the debtors argue that the debts are in the nature of open accounts under Alabama law, and that the applicable statute is therefore…”
Stanley L. Crawford v. LVNV Funding, LLC, 758 F.3d 1254 (11th Cir. 2014). “See Ala.Code § 6-2-37(1). Then, on February 2, 2008, Crawford filed for Chapter 13 bankruptcy in the Middle District of Alabama.”
Stacey v. Peed, 142 So. 3d 529 (Ala. 2013). “Section 6-2-37, Ala.Code 1975, provides that "[a]ctions to recover money due by open or unliquidated account” must be commenced within three years of “the date of the last item of the account or from the time when, by contract or usage, the account is due.”
Kimber v. Fed. Fin. Corp., 668 F. Supp. 1480 (M.D. Ala. 1987). “Where a stated account or simple contract is at issue, the Alabama Code of 1975, § 6-2-34(5) and (9) provides for a six year period; on an open account, a three year period applies, pursuant to § 6-2-37(1). Regardless of which statute is applied to Kimber’s alleged debt, the…”
Wal-Mart Stores, Inc. v. Anniston Dev. Co., 853 So. 2d 218 (Ala. 2002). “The overpayment was made more than three years before this action was filed. In its motion for a summary judgment ADC argued that the three-year statutory period of limitations for an action for money due by open or unliquidated account (Ala.”
Tuscaloosa Cnty. v. Child.'s Hosp., Inc., 486 So. 2d 1302 (Ala. Civ. App. 1986). “Children’s Hospital contends that the applicable statute of limitations is § 6-2-37, Code 1975. That section sets a three-year limitation for the commencement of an action to recover money due by account.”
McKerall v. Kaiser, 60 So. 3d 288 (Ala. 2010). “” Kaiser contends that, under § 6-2-37, his claim against McKerall did not accrue until May 1, 2007, and, therefore, that the applicable statute of limitations for count one did not expire until May 1, 2010.”
Cook v. Midland Funding, LLC, 208 So. 3d 1153 (Ala. Civ. App. 2016). “Next, Cook contends that one of Midland’s claims should be considered to be a claim on an open account subject to the three-year statute of limitations provided by § 6-2-37, Ala.Code 1975, rather than on an account stated subject to the six-year statute of limitations provided…”
Mobile Rug Shade Co. Inc. v. Daniel, 424 So. 2d 1332 (Ala. Civ. App. 1983). “Daniel’s answer included a defense that every matter sued upon was barred by the three year statute of limitations, § 6-2-37(1) of the Code of Alabama 1975. He later filed a motion for a summary judgment which was granted by the trial court.”
Home Indem. Co. v. Ball-Co Contractors, Inc., 645 F. Supp. 25 (S.D. Ala. 1986). “The ultimate amount due on Policy Number WC 9849538 has been objected to by the defendant, and the defendant has refused to pay any further amount allegedly due on that policy.”
Wilhite v. Beasley, 497 So. 2d 103 (Ala. 1986). “These items of open account were within the three-year statute of limitations, Code 1975, § 6-2-37, so any error in denying the motion for directed verdict on items of open account older than three years before the complaint was filed in August 1983 was harmless.”
The Home Indem. Co., Cross-Appellee v. Ball-Co Contractors, Inc., Cross-Appellant, 819 F.2d 1053 (11th Cir. 1987). “Ala. Code § 6-2-37 , 645 F.Supp. 25 (S.D.”
— Ala. Code § 6-2-37(1) — 7 cases
Stanley L. Crawford v. LVNV Funding, LLC, 758 F.3d 1254 (11th Cir. 2014). “See Ala.Code § 6-2-37(1). Then, on February 2, 2008, Crawford filed for Chapter 13 bankruptcy in the Middle District of Alabama.”
Kimber v. Fed. Fin. Corp., 668 F. Supp. 1480 (M.D. Ala. 1987). “Where a stated account or simple contract is at issue, the Alabama Code of 1975, § 6-2-34(5) and (9) provides for a six year period; on an open account, a three year period applies, pursuant to § 6-2-37(1). Regardless of which statute is applied to Kimber’s alleged debt, the…”
Stacey v. Peed, 142 So. 3d 529 (Ala. 2013). “Section 6-2-37, Ala.Code 1975, provides that "[a]ctions to recover money due by open or unliquidated account” must be commenced within three years of “the date of the last item of the account or from the time when, by contract or usage, the account is due.”
Wal-Mart Stores, Inc. v. Anniston Dev. Co., 853 So. 2d 218 (Ala. 2002). “The overpayment was made more than three years before this action was filed. In its motion for a summary judgment ADC argued that the three-year statutory period of limitations for an action for money due by open or unliquidated account (Ala.”
Mobile Rug Shade Co. Inc. v. Daniel, 424 So. 2d 1332 (Ala. Civ. App. 1983). “Daniel’s answer included a defense that every matter sued upon was barred by the three year statute of limitations, § 6-2-37(1) of the Code of Alabama 1975. He later filed a motion for a summary judgment which was granted by the trial court.”
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