Code of Alabama

Ala. Code § 6-5-280 (2026)

Breach of Contract - Limitation on Actions.

✓ official Alabama Legislature (ALISON) text, current July 2026
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If a contract is entire, only one action can be commenced for breach thereof; but if it is severable or if the breaches occur at successive periods in an entire contract, as where money is to be paid by installments, an action will lie for each breach; provided, that all the breaches occurring up to the commencement of the action must be included therein.

(Code 1907, §2505; Code 1923, §5721; Code 1940, T. 7, §140.)

Notes of Decisions
Cited in 6 cases (1 in the last 5 years), 1996–2025 · leading case: Bowdoin Square, LLC v. Winn-Dixie Montgomery, Inc., 873 So. 2d 1091 (Ala. 2003).
Bowdoin Square, LLC v. Winn-Dixie Montgomery, Inc., 873 So. 2d 1091 (Ala. 2003). · cites it 2× “Specifically, Bowdoin Square contends that it is entitled to the total amount of lease payments due under the 20-year lease, regardless of whether the payments had accrued before Winn-Dixie terminated the lease.”
Gregory v. Chem. Waste Mgmt., Inc., 38 F. Supp. 2d 598 (W.D. Tenn. 1996). “Alabama Code § 6-5-280 provides that If a contract is entire, only one action can be commenced for breach thereof; but if it is severable or if the breaches occur at successive periods in an entire contract, as where money is to be paid by installments, an action will lie for…”
Advance Trust & Life Escrow Servs., LTA v. Prot. Life Ins. Co. (N.D. Ala. 2019). · cites it 20× “And without opining as to the frequency of this duty, the court concludes that Advance Trust’s complaint allows for the reasonable inference that Protective Life incurred and ignored that duty most recently within the six years prior to Advance Trust filing this action.”
Gordon Ripps v. D. Leon Powers, 356 F. App'x 352 (11th Cir. 2009). “See Ala.Code § 6-5-280 (“[I]f the breaches occur at successive periods in an entire contract .”
Matthews v. Ankor Energy, LLC (S.D. Ala. 2018). · cites it 6× “12, citing ALA CODE § 6-5-280). The statute states the following: If a contract is entire, only one action can be commenced for breach thereof; but if it is severable or if the breaches occur at successive periods in an entire contract, as where money is to be paid by…”
Bryant Bank v. Jackson, as the Indep. of the Probat (Bankr. W.D. Tex. 2025). “Ala. Code § 6-5-280 (2024); see also Liddel v.”
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