burden-shifting analysis (Alabama) · Go Syfert
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burden-shifting analysis in Alabama

10 Alabama opinions name it 3 courts 1991–2023 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 (5)

CaseFollowedCited
Wiggins v. Stapleton Baptist Churchgreen
ala · 1968 · cited in 2 Alabama opinions naming this issue, 2006–2008
2 sentences

2008When the [defendant] shows legal title to the land, the burden of avoiding it by showing superior title by adverse possession (or by a better paper title) shifts to the [plaintiff].’ ” 947 So.2d at 1036 (quoting Wiggins v. Stapleton Baptist Church, 282 Ala. 255, 257 , 210 So.2d 814, 816-17 (1968)).

2008When the [defendant] shows legal title to the land, the burden of avoiding it by showing superior title by adverse possession (or by a better paper title) shifts to the [plaintiff].’ ” 947 So.2d at 1036 (quoting Wiggins v. Stapleton Baptist Church, 282 Ala. 255, 257 , 210 So.2d 814, 816-17 (1968)).

22
Ryan v. Hayesgreen
ala · 2002 · cited in 2 Alabama opinions naming this issue, 2006–2006
2 sentences

2006Ex parte Wood, 852 So.2d at 709 (citing Ryan v. Hayes, 831 So.2d 21, 28 (Ala.2002)).

2006Ex parte Wood, 852 So.2d at 709 (citing Ryan v. Hayes, 831 So.2d 21, 28 (Ala.2002)).

22
Cobb v. MacMillan Bloedel, Inc.green
ala · 1992 · cited in 1 Alabama opinions naming this issue, 2008–2008
1 sentence

2008First, the plaintiff must prove “actual or constructive possession of the property and that [that] possession was peaceable, as distinguished from scrambling or disputed.” Cobb v. MacMillan Bloedel, Inc., 604 So.2d 344, 345 (Ala.1992).

11
MacHen v. Wildergreen
ala · 1968 · cited in 1 Alabama opinions naming this issue, 2006–2006
2 sentences

2006When the [defendant] shows legal title to the land, the burden of avoiding it by showing superior title by adverse possession (or by a better paper title) shifts to the [plaintiff]." Wiggins v. Stapleton Baptist Church, 282 Ala. 255, 257 , 210 So.2d 814, 816-17 (1968) (citing Stewart v. Childress, 269 Ala. 87, 92 , 111 So.2d 8 (1959); and Webb v. King, 268 Ala. 282 , 105 So.2d 653 (1958)). [5] See *1037 also Machen v. Wilder, 283 Ala. 205, 208 , 215 So.2d 282, 284 (1968) ("In a statutory suit to quiet title, a prima facie case is made where it is shown that the [plaintiff] is in the peaceful p

2006When the [defendant] shows legal title to the land, the burden of avoiding it by showing superior title by adverse possession (or by a better paper title) shifts to the [plaintiff]." Wiggins v. Stapleton Baptist Church, 282 Ala. 255, 257 , 210 So.2d 814, 816-17 (1968) (citing Stewart v. Childress, 269 Ala. 87, 92 , 111 So.2d 8 (1959); and Webb v. King, 268 Ala. 282 , 105 So.2d 653 (1958)). [5] See *1037 also Machen v. Wilder, 283 Ala. 205, 208 , 215 So.2d 282, 284 (1968) ("In a statutory suit to quiet title, a prima facie case is made where it is shown that the [plaintiff] is in the peaceful p

11
Nellie F. Welsh, Administratrix of the Estate of Francis John Welsh, Deceased, and Nellie Welsh, Individually v. United Statesgreen
ca6 · 1988 · cited in 1 Alabama opinions naming this issue, 2000–2000
2 sentences

2000A burden-shifting instruction in the case of a merely negligent loss would not require the innocent party to suffer the consequences resulting from the fact that his or her burden of proof has been made greater by the negligence of the adversary, and, at the same time, it would not impose an excessively harsh sanction upon a merely negligent party." This burden-shift derives from the rationale set forth by the United States Court of Appeals for the Sixth Circuit in Welsh v. United States , 844 F.2d 1239 , 1248 (6th Cir. 1988).

2000A burden-shifting instruction in the case of a merely negligent loss would not require the innocent party to suffer the consequences resulting from the fact that his or her burden of proof has been made greater by the negligence of the adversary, and, at the same time, it would not impose an excessively harsh sanction upon a merely negligent party." This burden-shift derives from the rationale set forth by the United States Court of Appeals for the Sixth Circuit in Welsh v. United States, 844 F.2d 1239, 1248 (6th Cir.1988).

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 (10)

CaseCitedYears
Ex Parte Wood green
ala · 2002
2 sentences

2006Therefore, applying the burden-shifting analysis articulated in Ex parte Wood, 852 So.2d at 709 , we hold that Owens and Strength have established a clear legal right to a summary judgment based on State-agent immunity on Sanders’s claims against them relating to the hiring of Holmes.

2006Therefore, applying the burden-shifting analysis articulated in Ex parte Wood, 852 So.2d at 709 , we hold that Owens and Strength have established a clear legal right to a summary judgment based on State-agent immunity on Sanders's claims against them relating to the hiring of Holmes. *1028 C.

22006–2006
Herring v. Parkman green
ala · 1994
1 sentence

2023In Herring, the plaintiffs alleged that the defendant had breached the standard of care by advising them not to testify at trial. 631 So. 2d at 1002 .

12023–2023
Robinson v. Alabama Cent. Credit Union green
ala · 2007
1 sentence

2009Robinson, 964 So.2d at 1228-29 . “[Fjederal courts considering the issue [of the burden of proof applicable to an AADEA claim] have noted that the purpose and prohibitions of the AADEA are similar to those of the federal Age Discrimination in Employment Act, 29 U.S.C. § 621 et seq. (‘ADEA’), and concluded that ADEA principles should therefore govern in AADEA cases as well.

12009–2009
Woodland Grove Baptist Church v. WOODLAND GROVE COMMUNITY CEMETERY ASSOCIATION green
ala · 2006
1 sentence

2008When the [defendant] shows legal title to the land, the burden of avoiding it by showing superior title by adverse possession (or by a better paper title) shifts to the [plaintiff].’ ” 947 So.2d at 1036 (quoting Wiggins v. Stapleton Baptist Church, 282 Ala. 255, 257 , 210 So.2d 814, 816-17 (1968)).

12008–2008
Webb v. King neutral
ala · 1958
2 sentences

2006When the [defendant] shows legal title to the land, the burden of avoiding it by showing superior title by adverse possession (or by a better paper title) shifts to the [plaintiff]." Wiggins v. Stapleton Baptist Church, 282 Ala. 255, 257 , 210 So.2d 814, 816-17 (1968) (citing Stewart v. Childress, 269 Ala. 87, 92 , 111 So.2d 8 (1959); and Webb v. King, 268 Ala. 282 , 105 So.2d 653 (1958)). [5] See *1037 also Machen v. Wilder, 283 Ala. 205, 208 , 215 So.2d 282, 284 (1968) ("In a statutory suit to quiet title, a prima facie case is made where it is shown that the [plaintiff] is in the peaceful p

2006When the [defendant] shows legal title to the land, the burden of avoiding it by showing superior title by adverse possession (or by a better paper title) shifts to the [plaintiff]." Wiggins v. Stapleton Baptist Church, 282 Ala. 255, 257 , 210 So.2d 814, 816-17 (1968) (citing Stewart v. Childress, 269 Ala. 87, 92 , 111 So.2d 8 (1959); and Webb v. King, 268 Ala. 282 , 105 So.2d 653 (1958)). [5] See *1037 also Machen v. Wilder, 283 Ala. 205, 208 , 215 So.2d 282, 284 (1968) ("In a statutory suit to quiet title, a prima facie case is made where it is shown that the [plaintiff] is in the peaceful p

12006–2006
Gardner v. Key green
ala · 1991
1 sentence

2006The holding in Gardner v. Key, 594 So.2d 43 (Ala.1992), does not apply to this case for two reasons.

12006–2006
Stewart v. Childress green
ala · 1959
2 sentences

2006When the [defendant] shows legal title to the land, the burden of avoiding it by showing superior title by adverse possession (or by a better paper title) shifts to the [plaintiff]." Wiggins v. Stapleton Baptist Church, 282 Ala. 255, 257 , 210 So.2d 814, 816-17 (1968) (citing Stewart v. Childress, 269 Ala. 87, 92 , 111 So.2d 8 (1959); and Webb v. King, 268 Ala. 282 , 105 So.2d 653 (1958)). [5] See *1037 also Machen v. Wilder, 283 Ala. 205, 208 , 215 So.2d 282, 284 (1968) ("In a statutory suit to quiet title, a prima facie case is made where it is shown that the [plaintiff] is in the peaceful p

2006When the [defendant] shows legal title to the land, the burden of avoiding it by showing superior title by adverse possession (or by a better paper title) shifts to the [plaintiff]." Wiggins v. Stapleton Baptist Church, 282 Ala. 255, 257 , 210 So.2d 814, 816-17 (1968) (citing Stewart v. Childress, 269 Ala. 87, 92 , 111 So.2d 8 (1959); and Webb v. King, 268 Ala. 282 , 105 So.2d 653 (1958)). [5] See *1037 also Machen v. Wilder, 283 Ala. 205, 208 , 215 So.2d 282, 284 (1968) ("In a statutory suit to quiet title, a prima facie case is made where it is shown that the [plaintiff] is in the peaceful p

12006–2006
Ford v. Washington green
ala · 1972
1 sentence

2006Ford v. Washington, 259 So.2d 226 (Ala.1972)." The trial court's recitation of the applicable caselaw, however, is incomplete; it does not articulate the complete burden-shifting analysis.

12006–2006
Campbell v. Williams green
ala · 1994
1 sentence

2004A burden-shifting instruction in the case of a merely negligent loss would not require the innocent party to suffer the consequences resulting from the fact that his or her burden of proof has been made greater by the negligence of the adversary, and, at the same time, it would not impose an excessively harsh sanction upon a merely negligent party." See also the adverse-interest charges approved in Murray and in Campbell v. Williams , 638 So.2d 804 (Ala. 1994).

12004–2004
Harold Glenn Williams v. Ralph Kemp, Warden, Georgia Diagnostic and Classification Center, Respondent green
ca11 · 1988
1 sentence

1991Williams v. Kemp , 846 F.2d 1276 , 1283-84 (11th Cir. 1988), cert. denied , [___] U.S. [___,] 110 S.Ct. 1836 [ 108 L.Ed.2d 965 ] (1990); . . .

11991–1991

Statutes the citing opinions construe

AL § Ala. Code § 6-6-540 (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

TX 256 (1985–2026) OH 203 (1990–2026) CA 190 (1985–2026) MI 113 (1980–2026) NJ 79 (1991–2026) CT 65 (1988–2026) TN 52 (1999–2026) NY 48 (1980–2026) WA 41 (1981–2025) MA 38 (1980–2026) PA 35 (1976–2026) KY 32 (2005–2026) FL 32 (1988–2026) GA 30 (1981–2025) ME 29 (2003–2025) LA 28 (1992–2023) IN 27 (1991–2026) MN 26 (1997–2025) MO 25 (1998–2025) NC 24 (2005–2025) IL 24 (1998–2026) OR 23 (1994–2026) IA 23 (1985–2026) KS 22 (1979–2024) VT 21 (1982–2025) RI 20 (2001–2019) HI 18 (1996–2025) DC 17 (1995–2026) WV 14 (1982–2025) MD 14 (1976–2026) UT 12 (1999–2025) ID 11 (1980–2023) VA 11 (1990–2026) AZ 10 (1982–2026) WI 10 (1979–2025) AL 10 (1991–2023) CO 10 (1990–2025) NV 10 (2020–2025) NE 10 (2006–2024) DE 8 (2011–2025) SC 7 (1984–1996) NM 7 (1991–2025) AK 7 (1982–2022) SD 6 (2003–2019) MT 6 (1979–2007) MS 4 (2000–2020) NH 4 (2016–2025) WY 4 (2007–2018) OK 2 (2012–2020) ND 2 (2001–2004) AR 2 (1951–2011) PR 2 (2011–2026)

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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