history rule (Alabama) · Go Syfert
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history rule in Alabama

19 Alabama opinions name it 2 courts 1935–2024 1 in the last five years

The cases below were cited by Alabama courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (11)

CaseFollowedCited
Chevron Oil Co. v. Husonred
scotus · 1971 · cited in 7 Alabama opinions naming this issue, 1996–2012
2 sentences

2009In Griffin v. Unocal Corp., 990 So.2d 291 (Ala.2008), the County says, this Court embraced the three factors outlined in Chevron Oil Co. v. Huson, 404 U.S. 97, 106-07 , 92 S.Ct. 349 , 30 L.Ed.2d 296 (1971), for determining whether a decision should be applied prospectively: first, the decision “must establish a new principle of law, either by overruling clear past precedent on which litigants may have relied, ... or by deciding an issue of first impression whose resolution was not clearly foreshadowed”; second, the court “must ... weigh the merits and demerits in each case by looking to the pr

2009In Griffin v. Unocal Corp., 990 So.2d 291 (Ala.2008), the County says, this Court embraced the three factors outlined in Chevron Oil Co. v. Huson, 404 U.S. 97, 106-07 , 92 S.Ct. 349 , 30 L.Ed.2d 296 (1971), for determining whether a decision should be applied prospectively: first, the decision “must establish a new principle of law, either by overruling clear past precedent on which litigants may have relied, ... or by deciding an issue of first impression whose resolution was not clearly foreshadowed”; second, the court “must ... weigh the merits and demerits in each case by looking to the pr

37
Cates v. Bushgreen
ala · 1975 · cited in 2 Alabama opinions naming this issue, 1976–1978
2 sentences

1978See also Cates v. Bush, 293 Ala. 535 , 307 So.2d 6 (1975), where the history of the rule is traced.

1978See also Cates v. Bush, 293 Ala. 535 , 307 So.2d 6 (1975), where the history of the rule is traced.

22
Linkletter v. Walkerred
scotus · 1965 · cited in 8 Alabama opinions naming this issue, 1991–2012
2 sentences

2012Second, it has been stressed that ‘we must ... weigh the merits and demerits in each case by looking to the prior history of the rule in question, its purpose and effect, and whether retrospective operation will further or retard its operation.’ Linkletter v. Walker, [ 381 U.S. 618, 629 , 85 S.Ct. 1731, 1737-38 , 14 L.Ed.2d 601 (1965) ].

2012Second, it has been stressed that ‘we must ... weigh the merits and demerits in each case by looking to the prior history of the rule in question, its purpose and effect, and whether retrospective operation will further or retard its operation.’ Linkletter v. Walker, [ 381 U.S. 618, 629 , 85 S.Ct. 1731, 1737-38 , 14 L.Ed.2d 601 (1965) ].

18
Gaylon Hofer v. Mack Trucks, Inc.green
ca8 · 1993 · cited in 1 Alabama opinions naming this issue, 2015–2015
1 sentence

2015As noted above, Vulcan quoted Chief Justice Hooper's dissent in Ex parte Wal-Mart Stores, Inc., 682 So.2d 65, 68 (Ala.1996), for the rule requiring a “threshold showing of relevance.” The dissent in Wal-Mart in turn quoted a decision of the United States Court of Appeals for the Eighth Circuit in Hofer v. Mack Trucks, Inc., 981 F.2d 377, 380 (8th Cir.1992).

11
Ex Parte Wal-Mart Stores, Inc.green
ala · 1996 · cited in 1 Alabama opinions naming this issue, 2015–2015
1 sentence

2015As noted above, Vulcan quoted Chief Justice Hooper's dissent in Ex parte Wal-Mart Stores, Inc., 682 So.2d 65, 68 (Ala.1996), for the rule requiring a “threshold showing of relevance.” The dissent in Wal-Mart in turn quoted a decision of the United States Court of Appeals for the Eighth Circuit in Hofer v. Mack Trucks, Inc., 981 F.2d 377, 380 (8th Cir.1992).

11
Cline v. Ashland, Inc.green
ala · 2007 · cited in 1 Alabama opinions naming this issue, 2009–2009
2 sentences

2009In Griffin v. Unocal Corp., 990 So.2d 291 (Ala.2008), the County says, this Court embraced the three factors outlined in Chevron Oil Co. v. Huson, 404 U.S. 97, 106-07 , 92 S.Ct. 349 , 30 L.Ed.2d 296 (1971), for determining whether a decision should be applied prospectively: first, the decision “must establish a new principle of law, either by overruling clear past precedent on which litigants may have relied, ... or by deciding an issue of first impression whose resolution was not clearly foreshadowed”; second, the court “must ... weigh the merits and demerits in each case by looking to the pr

2009In Griffin v. Unocal Corp., 990 So.2d 291 (Ala.2008), the County says, this Court embraced the three factors outlined in Chevron Oil Co. v. Huson, 404 U.S. 97, 106-07 , 92 S.Ct. 349 , 30 L.Ed.2d 296 (1971), for determining whether a decision should be applied prospectively: first, the decision "must establish a new principle of law, either by overruling clear past precedent on which litigants may have relied,. . . or by deciding an issue of first impression whose resolution was not clearly foreshadowed"; second, the court "must . . . weigh the merits and demerits in each case by looking to the

11
Griffin v. Unocal Corp.green
ala · 2008 · cited in 1 Alabama opinions naming this issue, 2009–2009
2 sentences

2009In Griffin v. Unocal Corp., 990 So.2d 291 (Ala.2008), the County says, this Court embraced the three factors outlined in Chevron Oil Co. v. Huson, 404 U.S. 97, 106-07 , 92 S.Ct. 349 , 30 L.Ed.2d 296 (1971), for determining whether a decision should be applied prospectively: first, the decision “must establish a new principle of law, either by overruling clear past precedent on which litigants may have relied, ... or by deciding an issue of first impression whose resolution was not clearly foreshadowed”; second, the court “must ... weigh the merits and demerits in each case by looking to the pr

2009In Griffin v. Unocal Corp., 990 So.2d 291 (Ala.2008), the County says, this Court embraced the three factors outlined in Chevron Oil Co. v. Huson, 404 U.S. 97, 106-07 , 92 S.Ct. 349 , 30 L.Ed.2d 296 (1971), for determining whether a decision should be applied prospectively: first, the decision “must establish a new principle of law, either by overruling clear past precedent on which litigants may have relied, ... or by deciding an issue of first impression whose resolution was not clearly foreshadowed”; second, the court “must ... weigh the merits and demerits in each case by looking to the pr

11
Harkins & Co. v. Lewisgreen
ala · 1988 · cited in 1 Alabama opinions naming this issue, 2003–2003
2 sentences

2003NOTES [1] In Ex parte Liberty National, we discussed the history of the rule of repose and returned, through clarification, to the traditional meaning of the rule; namely, that "the 20-year period begins to run against claims the first time those claims could have been asserted, regardless of the claimant's notice of a claim." 825 So.2d at 764 (footnotes omitted). [2] See Harkins & Co. v. Lewis, 535 So.2d 104, 117 (Ala.1988). [3] A comparison of the language of Rule 15— "and leave shall be given only upon a showing of good cause"—with the alternative phrase "and leave shall be given upon a sho

2003MOORE, C.J., and LYONS and JOHNSTONE, JJ., dissent. 1 In Ex parte Liberty National , we discussed the history of the rule of repose and returned, through clarification, to the traditional meaning of the rule; namely, that "the 20-year period begins to run against claims the first time those claims could have been asserted, regardless of the claimant's notice of a claim." 825 So.2d at 764 (footnotes omitted). 2 See Harkins Co. v. Lewis , 535 So.2d 104 , 117 (Ala. 1988). 3 A comparison of the language of Rule 15 — "and leave shall be given only upon a showing of good cause" — with the alternativ

11
Ex Parte Liberty Nat. Life Ins. Co.green
ala · 2002 · cited in 1 Alabama opinions naming this issue, 2003–2003
2 sentences

2003MOORE, C.J., and LYONS and JOHNSTONE, JJ., dissent. 1 In Ex parte Liberty National , we discussed the history of the rule of repose and returned, through clarification, to the traditional meaning of the rule; namely, that "the 20-year period begins to run against claims the first time those claims could have been asserted, regardless of the claimant's notice of a claim." 825 So.2d at 764 (footnotes omitted). 2 See Harkins Co. v. Lewis , 535 So.2d 104 , 117 (Ala. 1988). 3 A comparison of the language of Rule 15 — "and leave shall be given only upon a showing of good cause" — with the alternativ

2003MOORE, C.J., and LYONS and JOHNSTONE, JJ., dissent. 1 In Ex parte Liberty National , we discussed the history of the rule of repose and returned, through clarification, to the traditional meaning of the rule; namely, that "the 20-year period begins to run against claims the first time those claims could have been asserted, regardless of the claimant's notice of a claim." 825 So.2d at 764 (footnotes omitted). 2 See Harkins Co. v. Lewis , 535 So.2d 104 , 117 (Ala. 1988). 3 A comparison of the language of Rule 15 — "and leave shall be given only upon a showing of good cause" — with the alternativ

11
Chavers v. National SEC. Fire & Cas. Co.green
ala · 1981 · cited in 1 Alabama opinions naming this issue, 1984–1984
1 sentence

1984The scope of review is settled: "A post-judgment motion for a new trial, grounded on a claim that `the verdict is against the great weight and preponderance of the evidence' should be granted only in extreme cases, when to let the verdict stand, though supported by some evidence, would be palpably wrong and manifestly unjust." Casey, supra , at 8; Ala.R.Civ.P. 50; see Chavers v. National Security Fire Casualty Co. , 405 So.2d 1 (Ala. 1981), for a discussion of the history of the standard, especially as it is applied to an alleged bad faith refusal to pay an insurance claim.

11
Maroney's Estategreen
pa · 1933 · cited in 1 Alabama opinions naming this issue, 1935–1935
2 sentences

1935In Re Maroney’s Estate, 311 Pa. 336, 338, 340, 341 , 166 A. 914 , decided in 1933, the questions presented were whether or not, “under section 41 of the Fiduciaries Act of June 7, 1917, P. L. 447, amended April 26, 1929, P L. 817, a trustee may invest in a first mortgage, secured upon real estate of a Pennsylvania corporation, accompanied by the single bond of the corporation to the trustee as sole obligee,” and whether or not the statute, if construed to so authorize, contravened the provisions of section 22 of article 3 of the Constitution of said state?

1935In Re Maroney’s Estate, 311 Pa. 336, 338, 340, 341 , 166 A. 914 , decided in 1933, the questions presented were whether or not, “under section 41 of the Fiduciaries Act of June 7, 1917, P. L. 447, amended April 26, 1929, P L. 817, a trustee may invest in a first mortgage, secured upon real estate of a Pennsylvania corporation, accompanied by the single bond of the corporation to the trustee as sole obligee,” and whether or not the statute, if construed to so authorize, contravened the provisions of section 22 of article 3 of the Constitution of said state?

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Alabama. Read the followed side critically anyway.

Also cited on this issue (12)

CaseCitedYears
Harper v. Virginia Department of Taxation green
scotus · 1993
2 sentences

2008Finally, we have weighed the inequity imposed by retroactive application, for “[w]here a decision of this Court could produce substantial inequitable results if applied retroactively, there is ample basis in our cases for avoiding the ‘injustice or hardship’ by a holding of nonretroac-tivity.” ’ “Chevron Oil Co. v. Huson, 404 U.S. 97, 106-07 , 92 S.Ct. 349, 355 , 30 L.Ed.2d 296 (1971)[, but see Harper v. Virginia Dep’t of Taxation, 509 U.S. 86 (1993) ].” McCullar v. Universal Underwriters Life Ins.

2008Finally, we have weighed the inequity imposed by retroactive application, for "[w]here a decision of this Court could produce substantial inequitable results if applied retroactively, there is ample basis in our cases for avoiding the `injustice or hardship' by a holding of nonretroactivity.'" " Chevron Oil Co. v. Huson, 404 U.S. 97, 106-07 , 92 S.Ct. 349, 355 , 30 L.Ed.2d 296 (1971)[, but see Harper v. Virginia Dep't of Taxation, 509 U.S. 86 (1993)]." McCullar v. Universal Underwriters Life Ins.

32007–2008
McCullar v. UNIV. UNDERWRITERS LIFE INS. green
ala · 1996
2 sentences

2012Finally, we have weighed the inequity imposed by retroactive application, for ‘[wjhere a decision of this Court could produce substantial inequitable results if applied retroactively, there is ample basis in our cases for avoiding the “injustice or hardship” by a holding of nonretroactivity.’ ” ’ “687 So.2d at 165 (quoting Chevron Oil, 404 U.S. at 106-07 , 92 S.Ct. at 355 , 30 L.Ed.2d at 296 (1971)).” 718 So.2d at 24 .

1998Finally, we have weighed the inequity imposed by retroactive application, for "[w]here a decision of this Court could produce substantial inequitable results if applied retroactively, there is ample basis in our cases for avoiding the `injustice or hardship' by holding of nonretroactivity."'" 687 So.2d at 165 (quoting Chevron Oil , 404 U.S. at 106 -07 , 92 S.Ct. at 355 , 30 L.Ed.2d at 296 (1971)).

21998–2012
Kennedy v. Bremerton School Dist. green
scotus · 2022
1 sentence

2024Dist., 597 U.S. 507 , 535- 36 (2022)).

12024–2024
First Tennessee Bank v. Snell green
ala · 1998
1 sentence

2012Finally, we have weighed the inequity imposed by retroactive application, for ‘[wjhere a decision of this Court could produce substantial inequitable results if applied retroactively, there is ample basis in our cases for avoiding the “injustice or hardship” by a holding of nonretroactivity.’ ” ’ “687 So.2d at 165 (quoting Chevron Oil, 404 U.S. at 106-07 , 92 S.Ct. at 355 , 30 L.Ed.2d at 296 (1971)).” 718 So.2d at 24 .

12012–2012
Hall Street Associates, L. L. C. v. Mattel, Inc. green
scotus · 2008
2 sentences

2010Subsequently, in Hall Street Associates, L.L.C. v. Mattel, Inc., 552 U.S. 576 , 128 S.Ct. 1396 , 170 L.Ed.2d 254 (2008), the United States Supreme Court rejected manifest disregard of the law as an available ground for reviewing arbitration awards under the FAA.

2010Subsequently, in Hall Street Associates, L.L.C. v. Mattel, Inc., 552 U.S. 576 , 128 S.Ct. 1396 , 170 L.Ed.2d 254 (2008), the United States Supreme Court rejected manifest disregard of the law as an available ground for reviewing arbitration awards under the FAA.

12010–2010
Birmingham News Co. v. Horn red
ala · 2004
1 sentence

2010This Court reviewed the history of the standard in the federal courts and in the appellate courts of other states and then concluded: “This Court joins the majority of other state appellate courts that have considered the matter in now recognizing ‘manifest disregard of the lav^ as a ground available for reviewing an arbitration award.” 901 So.2d at 50 .

12010–2010
Hewlett v. George red
miss · 1891
1 sentence

2003We discussed the history of the doctrine in this State, and the rationale for crafting an exception, in Hurst : "The parental immunity doctrine had its genesis in the United States in Hewellette v. George, 68 Miss. 703 , 9 So. 885 (1891), abrogated by Glaskox v. Glaskox, 614 So.2d 906 (Miss.1992), in which a minor daughter was precluded from suing her deceased mother's estate for damages resulting from mental suffering and injury to her character incurred during her confinement in an asylum for 11 days caused by her mother.

12003–2003
Glaskox by and Through Denton v. Glaskox green
miss · 1992
1 sentence

2003We discussed the history of the doctrine in this State, and the rationale for crafting an exception, in Hurst : "The parental immunity doctrine had its genesis in the United States in Hewellette v. George, 68 Miss. 703 , 9 So. 885 (1891), abrogated by Glaskox v. Glaskox, 614 So.2d 906 (Miss.1992), in which a minor daughter was precluded from suing her deceased mother's estate for damages resulting from mental suffering and injury to her character incurred during her confinement in an asylum for 11 days caused by her mother.

12003–2003
Oehmig v. Johnson green
ala · 1994
2 sentences

2003Furthermore, Oehmig was not decided on the basis of this incorrect statement; rather, Oehmig was decided on the basis that the rule of repose could not be used offensively (in a manner similar to the concept of adverse possession) `against one with valid record title by one who clearly does not have title' in order to divest the title owner of property. 638 So.2d at 850 .

2003Furthermore, Oehmig was not decided on the basis of this incorrect statement; rather, Oehmig was decided on the basis that the rule of repose could not be used offensively (in a manner similar to the concept of adverse possession) `against one with valid record title by one who clearly does not have title' in order to divest the title owner of property. 638 So.2d at 850 .

12003–2003
Hutchinson v. Board of Trustees of University of Alabama green
· 1971
2 sentences

2000Development of the Doctrine of Immunity We today reexamine the doctrine of immunity of officers, agents, and employees of the State for torts committed in the course of their performance of their duties. [2] We begin our discussion with a review of the doctrine of immunity where the issue *397 arises in the context of the immunity available to the State in an action against the State ("State immunity") as opposed to the immunity available to individual defendants sued for actions taken on behalf of the State ("State-agent immunity"). [3] In Hutchinson v. Board of Trustees of University of Alab

2000Development of the Doctrine of Immunity We today reexamine the doctrine of immunity of officers, agents, and employees of the State for torts committed in the course of their performance of their duties. [2] We begin our discussion with a review of the doctrine of immunity where the issue *397 arises in the context of the immunity available to the State in an action against the State ("State immunity") as opposed to the immunity available to individual defendants sued for actions taken on behalf of the State ("State-agent immunity"). [3] In Hutchinson v. Board of Trustees of University of Alab

12000–2000
Casey v. Jones green
ala · 1981
1 sentence

1984The scope of review is settled: "A post-judgment motion for a new trial, grounded on a claim that `the verdict is against the great weight and preponderance of the evidence' should be granted only in extreme cases, when to let the verdict stand, though supported by some evidence, would be palpably wrong and manifestly unjust." Casey, supra , at 8; Ala.R.Civ.P. 50; see Chavers v. National Security Fire Casualty Co. , 405 So.2d 1 (Ala. 1981), for a discussion of the history of the standard, especially as it is applied to an alleged bad faith refusal to pay an insurance claim.

11984–1984
Powell v. Republic National Life Insurance Co. green
ala · 1974
2 sentences

1976Because it is subject to revision, it is not a final judgment and will not support an appeal.” Powell v. Republic National Life Insurance Co. et al., 293 Ala. 101 , 300 So.2d 359 (1974); See also Cates v. Bush, 293 Ala. 535 , 307 So.2d 6 (1975), where the history of the rule is traced.

1976Because it is subject to revision, it is not a final judgment and will not support an appeal.” Powell v. Republic National Life Insurance Co. et al., 293 Ala. 101 , 300 So.2d 359 (1974); See also Cates v. Bush, 293 Ala. 535 , 307 So.2d 6 (1975), where the history of the rule is traced.

11976–1976

Statutes the citing opinions construe

AL § Ala. Code § 6-2-30 (4) AL § Ala. Code § 6-2-3 (3) AL § Ala. Code § 6-2-38 (3) AL § Ala. Code § 6-5-547 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

PA 74 (1863–2024) CA 57 (1880–2026) TX 50 (1878–2023) NM 42 (1970–2025) WA 41 (1906–2025) NJ 40 (1925–2023) LA 40 (1934–2025) MD 39 (1966–2023) IL 34 (1924–2022) FL 30 (1959–2023) NY 29 (1892–2008) GA 28 (1900–2025) TN 26 (1940–2022) OR 25 (1954–2025) MO 23 (1888–2018) MI 23 (1944–2024) AL 19 (1935–2024) OH 17 (1913–2023) IA 15 (1885–2021) SD 15 (1974–2025) CO 14 (1946–2025) UT 14 (1949–2021) VA 13 (1954–2025) MN 13 (1969–2006) ND 13 (1916–2005) WI 13 (1926–2023) CT 12 (1968–2016) WY 12 (1975–2015) AZ 12 (1960–2014) KY 12 (1922–2018) MT 10 (1916–2025) IN 9 (1958–2020) DC 9 (1946–2007) ID 9 (1951–2022) NC 9 (1973–2000) KS 9 (1905–2013) AR 8 (1979–2003) MS 8 (1968–2008) WV 7 (1936–2018) OK 7 (1979–2024) MA 7 (1903–2003) RI 6 (1969–2020) AK 6 (1977–2025) VT 6 (1976–2017) SC 5 (1938–1990) HI 5 (1980–2022) DE 5 (1992–2018) NV 4 (1970–2013) NE 4 (1897–2019) NH 4 (1932–2003) PR 2 (1926–1929)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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