exhaustion doctrine (Alabama) · Go Syfert
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exhaustion doctrine in Alabama

16 Alabama opinions name it 2 courts 1980–2012 0 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 (7)

CaseFollowedCited
Hall v. City of Dothangreen
alacivapp · 1988 · cited in 6 Alabama opinions naming this issue, 1989–2011
2 sentences

2011Under that doctrine “ ‘judicial interference is withheld until the administrative process has run its course.’ ” Id. “ ‘In Hall v. City of Dothan, 539 So.2d 286 (Ala.Civ.App.1988), the Court of Civil Appeals discussed the purpose of the requirement that public employees exhaust administrative remedies before obtaining judicial review: “ ‘ “The exhaustion doctrine allows an agency to fully develop technical issues and factual records within its particular area of expertise prior to judicial review.

2009Entrekin approved the “exhaustion of administrative remedies” doctrine found in United States v. Western Pacific Railroad Co., 352 U.S. 59 , 77 S.Ct. 161 , 1 L.Ed.2d 126 (1956), which applies “where a claim is cognizable in the first instance by an administrative agency alone.” By that doctrine “judicial interference is withheld until the administrative process has run its course....” Entrekin, at 210, 314 So.2d 663 .’ “In Hall v. City of Dothan, 539 So.2d 286 (Ala.Civ.App.1988), the Court of Civil Appeals discussed the purpose of the requirement that public employees exhaust administrative re

26
Fraternal Order of Police, Strawberry Lodge 40 v. Entrekingreen
· 1975 · cited in 2 Alabama opinions naming this issue, 1995–2009
2 sentences

2009Entrekin approved the “exhaustion of administrative remedies” doctrine found in United States v. Western Pacific Railroad Co., 352 U.S. 59 , 77 S.Ct. 161 , 1 L.Ed.2d 126 (1956), which applies “where a claim is cognizable in the first instance by an administrative agency alone.” By that doctrine “judicial interference is withheld until the administrative process has run its course....” Entrekin, at 210, 314 So.2d 663 .’ “In Hall v. City of Dothan, 539 So.2d 286 (Ala.Civ.App.1988), the Court of Civil Appeals discussed the purpose of the requirement that public employees exhaust administrative re

1995Entrekin approved the 'exhaustion of administrative remedies' doctrine found in United States v. Western Pacific Railroad Co. , 352 U.S. 59 , 77 S.Ct. 161 , 1 L.Ed.2d 126 (1956), which applies 'where a claim is cognizable in the first instance by an administrative agency alone.' By that doctrine 'judicial interference is withheld until the administrative process has run its course. . . .' Entrekin , at 210, 314 So.2d 663 ." In Hall v. City of Dothan , 539 So.2d 286 (Ala.Civ.App. 1988), the Court of Civil Appeals discussed the purpose of the requirement that public employees exhaust administrat

22
Bateman v. Blue Cross-Blue Shield of Alabamagreen
almd · 1984 · cited in 2 Alabama opinions naming this issue, 1988–1989
2 sentences

1989The exhaustion requirement serves a number of purposes, among which are the following: “ ‘(1) to avoid premature interruption of the administrative process; (2) to let the agency develop the necessary factual background upon which decisions should be based; (3) to permit the agency to exercise its discretion or apply its expertise; (4) to improve the efficiency of the administrative process; (5) to conserve scarce judicial resources, since the complaining party may be successful in vindicating rights in the administrative process and the courts may never have to intervene; (6) to give the agen

1988See also McKart v. United States , 395 U.S. 185 , 193-94 , 89 S.Ct. 1657 , 1662-63 , 23 L.Ed.2d 194 (1969)." Bateman v. Blue Cross-Blue Shield of Alabama , 579 F. Supp. 265 , 267 (M.D.Ala. 1984).

22
Goolsby v. Greengreen
ala · 1983 · cited in 2 Alabama opinions naming this issue, 1988–1989
2 sentences

1989Hall, supra. These exceptions generally arise when: “ ‘(1) the question raised is one of an interpretation of a statute, (2) the action raises questions of law only and not matters requiring administrative findings of fact or the exercise of administrative discretion, (3) exhaustion of administrative remedies would be futile or the remedies provided would be inadequate, and (4) requiring exhaustion of administrative remedies would result in irreparable harm.’ ” Hall, supra, at 289 (quoting Goolsby v. Green, 431 So.2d 955, 958 (Ala.1983)).

1988Porter v. Schweiker, supra. Our supreme court has noted that these exceptions arise generally when: "(1) the question raised is one of an interpretation of a statute, (2) the action raises questions of law only and not matters requiring administrative findings of fact or the exercise of administrative discretion, (3) exhaustion of administrative remedies would be futile or the remedies provided would be inadequate, and (4) requiring exhaustion of administrative remedies would result in irreparable harm." Goolsby v. Green , 431 So.2d 955 , 958 (Ala. 1983).

12
Dwight E. Freeman v. Warden Francis Corrections Officer Shoemaker Nurse Kentgreen
ca6 · 1999 · cited in 1 Alabama opinions naming this issue, 2012–2012
1 sentence

2012A broad exhaustion requirement that includes excessive force claims effectuates this purpose and maximizes the benefits of requiring prisoners to use prison grievance procedures before coming to federal court.” Freeman v. Francis, 196 F.3d 641, 644 (6th Cir.1999) (emphasis added).

11
Smith v. Robinsonred
scotus · 1984 · cited in 1 Alabama opinions naming this issue, 1993–1993
2 sentences

1993See *165 Smith v. Robinson, 468 U.S. 992 [1015-16 n. 17], 104 S.Ct. 3457 , 3470-71 n. 17 [ 82 L.Ed.2d 746 ] (1984).

1993See *165 Smith v. Robinson, 468 U.S. 992 [1015-16 n. 17], 104 S.Ct. 3457 , 3470-71 n. 17 [ 82 L.Ed.2d 746 ] (1984).

11
McKart v. United Statesgreen
scotus · 1969 · cited in 1 Alabama opinions naming this issue, 1988–1988
2 sentences

1988See also McKart v. United States , 395 U.S. 185 , 193-94 , 89 S.Ct. 1657 , 1662-63 , 23 L.Ed.2d 194 (1969)." Bateman v. Blue Cross-Blue Shield of Alabama , 579 F. Supp. 265 , 267 (M.D.Ala. 1984).

1988See also McKart v. United States , 395 U.S. 185 , 193-94 , 89 S.Ct. 1657 , 1662-63 , 23 L.Ed.2d 194 (1969)." Bateman v. Blue Cross-Blue Shield of Alabama , 579 F. Supp. 265 , 267 (M.D.Ala. 1984).

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
United States v. Western Pacific Railroad green
scotus · 1956
2 sentences

2011Under that doctrine “ ‘judicial interference is withheld until the administrative process has run its course.’ ” Id. “ ‘In Hall v. City of Dothan, 539 So.2d 286 (Ala.Civ.App.1988), the Court of Civil Appeals discussed the purpose of the requirement that public employees exhaust administrative remedies before obtaining judicial review: “ ‘ “The exhaustion doctrine allows an agency to fully develop technical issues and factual records within its particular area of expertise prior to judicial review.

2009Entrekin approved the “exhaustion of administrative remedies” doctrine found in United States v. Western Pacific Railroad Co., 352 U.S. 59 , 77 S.Ct. 161 , 1 L.Ed.2d 126 (1956), which applies “where a claim is cognizable in the first instance by an administrative agency alone.” By that doctrine “judicial interference is withheld until the administrative process has run its course....” Entrekin, at 210, 314 So.2d 663 .’ “In Hall v. City of Dothan, 539 So.2d 286 (Ala.Civ.App.1988), the Court of Civil Appeals discussed the purpose of the requirement that public employees exhaust administrative re

31995–2011
City of Gadsden v. Entrekin green
ala · 1980
2 sentences

1996Ex parte Lake Forest Property Owners' Ass'n , 603 So.2d 1045 , 1047 (Ala. 1992); Entrekin , 387 So.2d at 833 .

1992City of Gadsden v. Entrekin, 387 So.2d 829 (Ala.1980).

31992–1996
Ella Porter v. Richard S. Schweiker, in His Official Capacity as Secretary of Health and Human Services green
ca11 · 1982
2 sentences

1999Porter v. Schweiker, [ 692 F.2d 740 , 742 (11th Cir. 1982)].

1988The exhaustion requirement serves a number of purposes, among which are these: "(1) to avoid premature interruption of the administrative process; (2) to let the agency develop the necessary factual background upon which decisions should be based; (3) to permit the agency to exercise its discretion or apply its expertise; (4) to improve the efficiency of the administrative process; (5) to conserve scarce judicial resources, since the complaining party may be successful in vindicating rights in the administrative process and the courts may never have to intervene; (6) to give the agency a chanc

21988–1999
Patsy v. Board of Regents of Fla. green
scotus · 1982
2 sentences

1988The exhaustion requirement serves a number of purposes, among which are these: "(1) to avoid premature interruption of the administrative process; (2) to let the agency develop the necessary factual background upon which decisions should be based; (3) to permit the agency to exercise its discretion or apply its expertise; (4) to improve the efficiency of the administrative process; (5) to conserve scarce judicial resources, since the complaining party may be successful in vindicating rights in the administrative process and the courts may never have to intervene; (6) to give the agency a chanc

1988The exhaustion requirement serves a number of purposes, among which are these: "(1) to avoid premature interruption of the administrative process; (2) to let the agency develop the necessary factual background upon which decisions should be based; (3) to permit the agency to exercise its discretion or apply its expertise; (4) to improve the efficiency of the administrative process; (5) to conserve scarce judicial resources, since the complaining party may be successful in vindicating rights in the administrative process and the courts may never have to intervene; (6) to give the agency a chanc

21988–1999
Ex Parte Lake Forest Property Owners'ass'n green
ala · 1992
2 sentences

1996Ex parte Lake Forest Property Owners' Ass'n , 603 So.2d 1045 , 1047 (Ala. 1992); Entrekin , 387 So.2d at 833 .

1994Further, we have considered Ex parte Lake Forest Property Owners’ Association, 603 So.2d 1045 (Ala.1992), and find that the exceptions to the exhaustion doctrine listed therein are inapplicable in the present case.

21994–1996
City of Huntsville v. Smartt green
ala · 1982
2 sentences

1996Citing Ex parte Graddick , 495 So.2d 1367 (Ala. 1986); Mobile Gulf R.R. v. Crocker , 455 So.2d 829 (Ala. 1984); and City of Huntsville v. Smartt , 409 So.2d 1353 (Ala. 1982), the College and Dr. Beaty argue that McLeod and Dinkins failed to exhaust the administrative remedies available to them.

1996Citing Ex parte Graddick, 495 So.2d 1367 (Ala.1986); Mobile & Gulf R.R. v. Crocker, 455 So.2d 829 (Ala.1984); and City of Huntsville v. Smartt, 409 So.2d 1353 (Ala.1982), the College and Dr. Beaty argue that McLeod and Dinkins failed to exhaust the administrative remedies available to them.

11996–1996
Faulkner v. University of Tennessee green
ala · 1992
2 sentences

1996In Faulkner v. University of Tennessee , supra, our supreme court noted that a circuit court should not enter a summary judgment (which is a judgment on the merits) if the circuit court concludes that, because of the application of the exhaustion doctrine, the circuit court does not have jurisdiction to adjudicate the claim. 627 So.2d at 364 .

1996In Faulkner v. University of Tennessee , supra, our supreme court noted that a circuit court should not enter a summary judgment (which is a judgment on the merits) if the circuit court concludes that, because of the application of the exhaustion doctrine, the circuit court does not have jurisdiction to adjudicate the claim. 627 So.2d at 364 .

11996–1996
Ex Parte Graddick green
ala · 1986
2 sentences

1996Citing Ex parte Graddick , 495 So.2d 1367 (Ala. 1986); Mobile Gulf R.R. v. Crocker , 455 So.2d 829 (Ala. 1984); and City of Huntsville v. Smartt , 409 So.2d 1353 (Ala. 1982), the College and Dr. Beaty argue that McLeod and Dinkins failed to exhaust the administrative remedies available to them.

1996Citing Ex parte Graddick, 495 So.2d 1367 (Ala.1986); Mobile & Gulf R.R. v. Crocker, 455 So.2d 829 (Ala.1984); and City of Huntsville v. Smartt, 409 So.2d 1353 (Ala.1982), the College and Dr. Beaty argue that McLeod and Dinkins failed to exhaust the administrative remedies available to them.

11996–1996
Mobile & Gulf R. Co. v. Crocker green
ala · 1984
2 sentences

1996Citing Ex parte Graddick , 495 So.2d 1367 (Ala. 1986); Mobile Gulf R.R. v. Crocker , 455 So.2d 829 (Ala. 1984); and City of Huntsville v. Smartt , 409 So.2d 1353 (Ala. 1982), the College and Dr. Beaty argue that McLeod and Dinkins failed to exhaust the administrative remedies available to them.

1996Citing Ex parte Graddick, 495 So.2d 1367 (Ala.1986); Mobile & Gulf R.R. v. Crocker, 455 So.2d 829 (Ala.1984); and City of Huntsville v. Smartt, 409 So.2d 1353 (Ala.1982), the College and Dr. Beaty argue that McLeod and Dinkins failed to exhaust the administrative remedies available to them.

11996–1996
Panola Land Buyers Association v. Shuman green
ca11 · 1985
1 sentence

1991Courts will not require exhaustion when the administrative remedy is inadequate because it does not exist, or would not provide relief commensurate with the claim, or would unreasonably delay the action and thereby create a serious risk of irreparable injury.’ Panola Land Buyers Ass’n v. Shuman, 762 F.2d 1550 , 1556 (11th Cir.1985) (citations omitted; emphasis added).

11991–1991
cluster 384395 green
ca5 · 1981
1 sentence

1988The exhaustion requirement serves a number of purposes, among which are these: "(1) to avoid premature interruption of the administrative process; (2) to let the agency develop the necessary factual background upon which decisions should be based; (3) to permit the agency to exercise its discretion or apply its expertise; (4) to improve the efficiency of the administrative process; (5) to conserve scarce judicial resources, since the complaining party may be successful in vindicating rights in the administrative process and the courts may never have to intervene; (6) to give the agency a chanc

11988–1988
Watson v. Norris green
ala · 1968
2 sentences

1980In addition to these authorities and the cases cited therein, this Court in Watson v. Norris , 283 Ala. 380 , 217 So.2d 246 (1969), applied the exhaustion doctrine in a case involving an attack upon a zoning administrator's denial of a use permit.

1980In addition to these authorities and the cases cited therein, this Court in Watson v. Norris , 283 Ala. 380 , 217 So.2d 246 (1969), applied the exhaustion doctrine in a case involving an attack upon a zoning administrator's denial of a use permit.

11980–1980

Statutes the citing opinions construe

USC § 42u.s.c.1983 (4) AL § Ala. Code § 11-52-81 (3) AL § Ala. Code § 36-26-100 (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

CA 418 (1897–2026) CT 286 (1979–2026) TX 203 (1973–2026) IL 189 (1963–2026) NY 151 (1974–2026) IN 98 (1979–2026) PA 93 (1954–2026) WA 71 (1984–2026) IA 70 (1972–2026) MD 61 (1980–2023) MA 52 (1976–2026) NJ 51 (1962–2024) WI 44 (1974–2026) FL 43 (1976–2025) MI 38 (1968–2026) AZ 37 (1963–2023) OH 36 (1975–2025) GA 36 (1980–2026) CO 36 (1974–2026) KS 36 (1974–2026) OR 35 (1974–2026) ID 29 (1978–2026) NV 28 (1992–2025) DC 27 (1985–2017) NM 27 (1966–2025) RI 27 (1966–2026) AK 27 (1981–2025) UT 24 (1992–2024) MT 24 (1981–2025) MO 23 (1957–2021) VT 21 (1986–2025) HI 20 (1987–2025) LA 19 (1989–2024) NC 18 (1991–2022) OK 18 (1977–2018) WY 17 (1982–2025) AL 16 (1980–2012) TN 16 (1995–2025) MN 15 (1981–2012) ME 15 (1984–2024) MS 14 (1963–2026) NE 14 (1998–2019) SD 13 (1975–2018) SC 12 (1990–2024) AR 11 (1996–2020) VA 11 (1982–2026) WV 9 (1989–2023) NH 6 (1989–2014) KY 5 (1981–2026) ND 5 (1997–2024) VI 2 (1988–1995) DE 2 (1975–2023)

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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