relationship privilege (Alabama) · Go Syfert
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relationship privilege in Alabama

14 Alabama opinions name it 3 courts 1956–2017 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 (5)

CaseFollowedCited
Sterling v. Stategreen
texapp · 1991 · cited in 2 Alabama opinions naming this issue, 2004–2015
2 sentences

2015Brown, 588 So.2d at 557 ; see also People v. Johnson, 284 Cal.Rptr. 579 , 233 Cal.App.3d 425 (1991) (statements made by a husband to his wife as he was beating her were not privileged because they were an abuse of the relationship on which the privilege was predicated); State v. Bryant, 56 Ohio App.3d 20 , 564 N.E.2d 709 (1988) (husband’s threats and abusive behavior toward his wife were not confidential communications and thus were not privileged); Sterling v. State, 814 S.W.2d 261, 262 (Tex.App. 1991) (husband’s abusive treatment of his wife was not a confidential communication).” 887 So.2d

2004Brown , 588 So.2d at 557 ; see also People v. Johnson , 284 Cal.Rptr. 579 , 233 Cal.App.3d 425 (1991) (statements made by a husband to his wife as he was beating her were not privileged because they were an abuse of the relationship on which the privilege was predicated); State v. Bryant , 56 Ohio App.3d 20 , 564 N.E.2d 709 (1988) (husband's threats and abusive behavior toward his wife were not confidential communications and thus were not privileged); Sterling v. State , 814 S.W.2d 261 , 262 (Tex.App. 1991) (husband's abusive treatment of his wife was not a confidential communication).

22
People v. Johnsongreen
calctapp · 1991 · cited in 2 Alabama opinions naming this issue, 2004–2015
2 sentences

2015Brown, 588 So.2d at 557 ; see also People v. Johnson, 284 Cal.Rptr. 579 , 233 Cal.App.3d 425 (1991) (statements made by a husband to his wife as he was beating her were not privileged because they were an abuse of the relationship on which the privilege was predicated); State v. Bryant, 56 Ohio App.3d 20 , 564 N.E.2d 709 (1988) (husband’s threats and abusive behavior toward his wife were not confidential communications and thus were not privileged); Sterling v. State, 814 S.W.2d 261, 262 (Tex.App. 1991) (husband’s abusive treatment of his wife was not a confidential communication).” 887 So.2d

2015Brown, 588 So.2d at 557 ; see also People v. Johnson, 284 Cal.Rptr. 579 , 233 Cal.App.3d 425 (1991) (statements made by a husband to his wife as he was beating her were not privileged because they were an abuse of the relationship on which the privilege was predicated); State v. Bryant, 56 Ohio App.3d 20 , 564 N.E.2d 709 (1988) (husband’s threats and abusive behavior toward his wife were not confidential communications and thus were not privileged); Sterling v. State, 814 S.W.2d 261, 262 (Tex.App. 1991) (husband’s abusive treatment of his wife was not a confidential communication).” 887 So.2d

22
T. C. Theatre Corp. v. Warner Bros. Pictures, Inc.green
nysd · 1953 · cited in 2 Alabama opinions naming this issue, 1981–1981
2 sentences

1981C. & Theatre Corporation v. Warner Brothers Pictures, Inc., 113 F.Supp. 265, 268-69 (S.D.N.Y. 1953): [T]he former client need show no more than that the matters embraced within the pending suit wherein his former attorney appears on behalf of his adversary are substantially related to the matters or cause of action wherein the attorney previously represented him, the former client.

1981C. & Theatre Corporation v. Warner Brothers Pictures, Inc., 113 F.Supp. 265, 268-69 (S.D.N.Y. 1953): [T]he former client need show no more than that the matters embraced within the pending suit wherein his former attorney appears on behalf of his adversary are substantially related to the matters or cause of action wherein the attorney previously represented him, the former client.

22
BP Oil Co. v. Jefferson Countygreen
ala · 1990 · cited in 3 Alabama opinions naming this issue, 2004–2017
2 sentences

2017In City of Alabaster v. Shelby Land Partners, LLC , 148 So.3d 697 , 704-05 (Ala. 2014), our supreme court explained the rules to be applied in determining whether a zoning classification and its application are valid in a given case: "In zoning cases, we have noted that there are two applicable rules: the 'substantial relationship rule' and the 'fairly debatable rule.' We explained the applicability of these two rules in BP Oil Co. v. Jefferson County , 571 So.2d 1026 (Ala. 1990) : " ' "The substantial relationship rule is a substantive law, and may be simply stated as follows: In order for a

2014In zoning cases, we have noted that there are two applicable rules: the “substantial relationship rule” and the “fairly debatable rule.” We explained the applicability of these two rules in BP Oil Co. v. Jefferson County, 571 So.2d 1026 (Ala.1990): “ ‘The substantial relationship rule is a substantive law, and may be simply stated as follows: In order for a zoning ordinance or regulation to be valid, it must have some substantial relationship to the promotion of the public health, safety, morals, or general welfare.

13
Byrd Companies, Inc. v. Jefferson Countygreen
ala · 1983 · cited in 1 Alabama opinions naming this issue, 2004–2004
2 sentences

2004In zoning cases, there are two applicable rules: the "substantial relationship rule" and the "fairly debatable rule." This Court explained the applicability of these two rules in BP Oil Co. v. Jefferson County, 571 So.2d 1026, 1028-29 (Ala.1990)(quoting Byrd Cos. v. Jefferson County, 445 So.2d 239, 247 (Ala.1983)): "`The substantial relationship rule is a substantive law, and may be simply stated as follows: In order for a zoning ordinance or regulation to be valid, it must have some substantial relationship to the promotion of the public health, safety, morals, or general welfare.

2004In zoning cases, there are two applicable rules: the "substantial relationship rule" and the "fairly debatable rule." This Court explained the applicability of these two rules in BP Oil Co. v. Jefferson County , 571 So.2d 1026 , 1028-29 (Ala. 1990) (quoting Byrd Cos. v. Jefferson County , 445 So.2d 239 , 247 (Ala. 1983)): "`The substantial relationship rule is a substantive law, and may be simply stated as follows: In order for a zoning ordinance or regulation to be valid, it must have some substantial relationship to the promotion of the public health, safety, morals, or general welfare.

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 (13)

CaseCitedYears
Brown v. State green
alacrimapp · 1991
2 sentences

2015Brown, 588 So.2d at 557 ; see also People v. Johnson, 284 Cal.Rptr. 579 , 233 Cal.App.3d 425 (1991) (statements made by a husband to his wife as he was beating her were not privileged because they were an abuse of the relationship on which the privilege was predicated); State v. Bryant, 56 Ohio App.3d 20 , 564 N.E.2d 709 (1988) (husband’s threats and abusive behavior toward his wife were not confidential communications and thus were not privileged); Sterling v. State, 814 S.W.2d 261, 262 (Tex.App. 1991) (husband’s abusive treatment of his wife was not a confidential communication).” 887 So.2d

2004Brown , 588 So.2d at 557 ; see also People v. Johnson , 284 Cal.Rptr. 579 , 233 Cal.App.3d 425 (1991) (statements made by a husband to his wife as he was beating her were not privileged because they were an abuse of the relationship on which the privilege was predicated); State v. Bryant , 56 Ohio App.3d 20 , 564 N.E.2d 709 (1988) (husband's threats and abusive behavior toward his wife were not confidential communications and thus were not privileged); Sterling v. State , 814 S.W.2d 261 , 262 (Tex.App. 1991) (husband's abusive treatment of his wife was not a confidential communication).

22004–2015
State v. Bryant green
ohioctapp · 1988
2 sentences

2015Brown, 588 So.2d at 557 ; see also People v. Johnson, 284 Cal.Rptr. 579 , 233 Cal.App.3d 425 (1991) (statements made by a husband to his wife as he was beating her were not privileged because they were an abuse of the relationship on which the privilege was predicated); State v. Bryant, 56 Ohio App.3d 20 , 564 N.E.2d 709 (1988) (husband’s threats and abusive behavior toward his wife were not confidential communications and thus were not privileged); Sterling v. State, 814 S.W.2d 261, 262 (Tex.App. 1991) (husband’s abusive treatment of his wife was not a confidential communication).” 887 So.2d

2015Brown, 588 So.2d at 557 ; see also People v. Johnson, 284 Cal.Rptr. 579 , 233 Cal.App.3d 425 (1991) (statements made by a husband to his wife as he was beating her were not privileged because they were an abuse of the relationship on which the privilege was predicated); State v. Bryant, 56 Ohio App.3d 20 , 564 N.E.2d 709 (1988) (husband’s threats and abusive behavior toward his wife were not confidential communications and thus were not privileged); Sterling v. State, 814 S.W.2d 261, 262 (Tex.App. 1991) (husband’s abusive treatment of his wife was not a confidential communication).” 887 So.2d

22004–2015
Fed. Sec. L. Rep. P 98,017 Carl R. Duncan, on Behalf of Himself and All Others Similarly Situated v. Merrill Lynch, Pierce, Fenner & Smith, Inc. green
ca5 · 1981
2 sentences

1990Co., our supreme court adopted the rationale of the Fifth Circuit in Duncan v. Merrill Lynch, Pierce, Fenner & Smith, 646 F.2d 1020 (5th Cir.1981): “ ‘Only when the moving party delineates with specificity the subject matters, issues, and causes of action presented in former representation can the district court determine if the substantial relationship test has been met.

1990Merely pointing to a superficial resemblance between the present and prior representations will not substitute for the careful comparison demanded by our cases.’ ” 469 So.2d at 575-76 , quoting Duncan, 646 F.2d at 1029 .

21985–1990
Fed. Sec. L. Rep. P 95,745 Dean Woods, and All Other Persons Similarly Situated v. Covington County Bank, Edward Hoglund v. Covington County Bank green
ca5 · 1976
2 sentences

1981This substantial relationship rule is followed in the majority of the jurisdictions and was followed by the Fifth Circuit Court of Appeals in Woods v. Covington County Bank, 537 F.2d 804 (5th Cir. 1976).

1981This substantial relationship rule is followed in the majority of the jurisdictions and was followed by the Fifth Circuit Court of Appeals in Woods v. Covington County *7 Bank, 537 F.2d 804 (5th Cir. 1976).

21981–1981
City of Alabaster v. Shelby Land Partners, LLC green
ala · 2014
1 sentence

2017In City of Alabaster v. Shelby Land Partners, LLC , 148 So.3d 697 , 704-05 (Ala. 2014), our supreme court explained the rules to be applied in determining whether a zoning classification and its application are valid in a given case: "In zoning cases, we have noted that there are two applicable rules: the 'substantial relationship rule' and the 'fairly debatable rule.' We explained the applicability of these two rules in BP Oil Co. v. Jefferson County , 571 So.2d 1026 (Ala. 1990) : " ' "The substantial relationship rule is a substantive law, and may be simply stated as follows: In order for a

12017–2017
Rich v. Rich green
alacivapp · 2004
1 sentence

2015Brown, 588 So.2d at 557 ; see also People v. Johnson, 284 Cal.Rptr. 579 , 233 Cal.App.3d 425 (1991) (statements made by a husband to his wife as he was beating her were not privileged because they were an abuse of the relationship on which the privilege was predicated); State v. Bryant, 56 Ohio App.3d 20 , 564 N.E.2d 709 (1988) (husband’s threats and abusive behavior toward his wife were not confidential communications and thus were not privileged); Sterling v. State, 814 S.W.2d 261, 262 (Tex.App. 1991) (husband’s abusive treatment of his wife was not a confidential communication).” 887 So.2d

12015–2015
Anderson v. State neutral
ala · 1996
2 sentences

2014The evidence was also sufficient to allow the jury to determine that Hand suffered “serious physical injuries.” ■ In Anderson v. State, 686 So.2d 381 (Ala.1996), the Alabama Supreme Court held that “testimony indicating] that.the victim had-a deep puncture wound from a knife; trauma to the head, along with various bruises and scrapes; a fractured rib; and a burst eardrum” was sufficient to establish that the victim had suffered “serious physical injuries.” 2 686 So.2d at 385 .

2014The evidence was also sufficient to allow the jury to determine that Hand suffered “serious physical injuries.” ■ In Anderson v. State, 686 So.2d 381 (Ala.1996), the Alabama Supreme Court held that “testimony indicating] that.the victim had-a deep puncture wound from a knife; trauma to the head, along with various bruises and scrapes; a fractured rib; and a burst eardrum” was sufficient to establish that the victim had suffered “serious physical injuries.” 2 686 So.2d at 385 .

12014–2014
Ex Parte Rush neutral
alacivapp · 1990
1 sentence

2005Ex parte Rush , 574 So.2d 808 , 810 (Ala.Civ.App. 1990). "`Only when the moving party delineates with specificity the subject matters, issues, and causes of action presented in former representation can the . . . court determine if the substantial relationship test has been met.

12005–2005
Ex Parte State Farm Mut. Auto. Ins. Co. green
ala · 1985
1 sentence

1990Merely pointing to a superficial resemblance between the present and prior representations will not substitute for the careful comparison demanded by our cases.’ ” 469 So.2d at 575-76 , quoting Duncan, 646 F.2d at 1029 .

11990–1990
Lehr v. Robertson green
scotus · 1983
2 sentences

1985Lehr v. Robertson, 463 U.S. 248 , 103 S.Ct. 2985 , 77 L.Ed.2d 614 (1983) (one claiming to be the natural father of a child placed for adoption had no standing to challenge the adoption because he had failed to establish a substantial relationship with the child in that he had never supported the child and had rarely seen her in the two years since her birth).

1985Lehr v. Robertson, 463 U.S. 248 , 103 S.Ct. 2985 , 77 L.Ed.2d 614 (1983) (one claiming to be the natural father of a child placed for adoption had no standing to challenge the adoption because he had failed to establish a substantial relationship with the child in that he had never supported the child and had rarely seen her in the two years since her birth).

11985–1985
Ex Parte Taylor Coal Co., Inc. green
ala · 1981
1 sentence

1985This Court in Ex parte Taylor Coal Co. emphasized that in adopting the substantial relationship test it was "adopting the majority view and that of the Fifth Circuit Court of Appeals." 401 So.2d at 7 .

11985–1985
Craig v. Boren green
scotus · 1976
2 sentences

1980Craig v. Boren , 429 U.S. 190 , 97 S.Ct. 451 , 50 L.Ed.2d 397 (1976).

1980Craig v. Boren , 429 U.S. 190 , 97 S.Ct. 451 , 50 L.Ed.2d 397 (1976).

11980–1980
Swendick v. Swendick green
ala · 1930
2 sentences

1956Swendick v. Swendick, 221 Ala. 337 , 128 So. 593 .

1956Swendick v. Swendick, 221 Ala. 337 , 128 So. 593 .

11956–1956

Statutes the citing opinions construe

AL § Ala. Code § 11-52-76 (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 68 (1959–2026) PA 50 (1925–2026) TX 43 (1990–2023) FL 33 (1975–2026) WA 32 (1965–2026) IL 28 (1976–2024) NJ 26 (1976–2026) NY 20 (1979–2024) NC 17 (2001–2025) CT 17 (1980–2019) WI 17 (1973–2025) AL 14 (1956–2017) MO 11 (1975–2020) MS 11 (1968–2025) MN 10 (1956–2017) AZ 9 (1982–2023) ID 9 (1982–2017) MA 9 (1987–2024) KS 8 (1965–2015) DE 8 (1990–2025) WV 8 (1981–2022) UT 8 (1953–2012) NM 7 (1980–2024) OK 7 (1990–2026) IN 6 (1979–2013) OH 6 (2000–2013) CO 6 (2001–2025) VT 6 (1998–2013) IA 6 (1971–2001) OR 6 (1977–2021) TN 5 (1936–2025) AK 5 (1967–2024) SD 5 (1992–2026) SC 5 (2012–2021) VA 4 (1988–2025) LA 4 (1989–2013) NV 4 (1996–2018) KY 3 (2006–2020) MI 3 (1998–2008) DC 3 (1987–1999) HI 3 (1972–2008) RI 2 (1991–2010) VI 2 (1992–2005) NH 2 (1980–1996) MD 2 (2011–2012)

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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