equitable estoppel doctrine (Alabama) · Go Syfert
← Alabama issues

equitable estoppel doctrine in Alabama

67 Alabama opinions name it 3 courts 1884–2026 2 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 (25)

CaseFollowedCited
Stamey v. Eastergreen
ala · 2000 · cited in 8 Alabama opinions naming this issue, 2000–2017
2 sentences

2017This Court has, however, crafted an exception to this equitable-estoppel exception: "Where 'the language of the arbitration provisions limited arbitration to the signing parties,' this Court has not allowed the claims against the nonsignatories to be arbitrated." Id. at 380-81 (quoting Stamey , 776 So.2d at 89 ).

2017In other words, "[i]f an arbitration agreement is written in broad language so that it applies to '[a]ll disputes, claims or controversies arising from or relating to this Contract or the relationships which result from this Contract ,' Ex parte Napier , 723 So.2d 49 , 51 (Ala. 1998) (emphasis added), or even in slightly narrower language so that it applies to 'ALL DISPUTES, CLAIMS OR CONTROVERSIES ARISING FROM OR RELATING TO THIS CONTRACT OR THE PARTIES THERETO ,' Stamey , 776 So.2d at 91 (capitalization in original; emphasis added), this Court will proceed to determine whether arbitration ma

88
Lambert v. Mail Handlers Benefit Plangreen
ala · 1996 · cited in 5 Alabama opinions naming this issue, 2004–2026
2 sentences

2026This court stated: " 'In order for the doctrine of equitable estoppel to apply, a party must demonstrate: " ' " '(1) That "[t]he person against whom estoppel is asserted, who usually must have knowledge of the facts, communicates something in a misleading way, either by words, conduct, or silence, with the intention that the communication will be acted on;" " ' " '(2) That "the person seeking to assert estoppel, who lacks knowledge of the facts, relies upon [the] communication;" and " ' " '(3) That "the person relying would be harmed materially if the actor is later permitted to 26 CL-2025-051

2015Draughon v. General Finance Credit Corp., 362 So.2d 880, 884 (Ala.1978).’ “Pierce v. Hand, Arendall, Bedsole, Greaves & Johnston, 678 So.2d 765, 768 (Ala.1996). ■“In order for the doctrine of equitable estoppel to apply, a party must demonstrate: ‘““(1) That ‘[t]he person against, whom estoppel is asserted, who usually must have knowledge of the facts, communicates something in a misleading way, either by words, conduct, or silence, with the intention that the communication will be acted on’; “ ‘ “(2) That ‘the person seeking to assert estoppel, who lacks knowledge of the facts, relies upon [t

35
Ex Parte Dyessgreen
ala · 1997 · cited in 5 Alabama opinions naming this issue, 2000–2008
2 sentences

2008Pursuant to the doctrine of equitable estoppel, a plaintiff may be compelled to arbitrate his or her claims against a nonsignatory to a contract containing an arbitration provision if the claims "are founded on, and are intertwined with, the facts surrounding the underlying contract that contains the arbitration clause." Ex parte Dyess , *Page 971 709 So.2d 447 , 451 (Ala. 1997).

2002Pursuant to the doctrine of equitable estoppel, a plaintiff may be compelled to arbitrate his or her claims against a nonsignatory to a contract containing an arbitration provision if the claims `are founded on, and are intertwined with, the facts surrounding the underlying contract that contains the arbitration clause.' Ex parte Dyess , 709 So.2d 447 , 451 (Ala. 1997).

35
Pierce v. Hand, Arendall, Bedsole, Greaves & Johnstongreen
ala · 1996 · cited in 3 Alabama opinions naming this issue, 2004–2015
2 sentences

2015Draughon v. General Finance Credit Corp., 362 So.2d 880, 884 (Ala.1978).’ “Pierce v. Hand, Arendall, Bedsole, Greaves & Johnston, 678 So.2d 765, 768 (Ala.1996). ■“In order for the doctrine of equitable estoppel to apply, a party must demonstrate: ‘““(1) That ‘[t]he person against, whom estoppel is asserted, who usually must have knowledge of the facts, communicates something in a misleading way, either by words, conduct, or silence, with the intention that the communication will be acted on’; “ ‘ “(2) That ‘the person seeking to assert estoppel, who lacks knowledge of the facts, relies upon [t

2007The State now petitions this Court to review the decision of the Court of Civil Appeals, and the main opinion of this Court, although acknowledging that the appeal was untimely, holds that under the doctrine of equitable estoppel Boutwell should be allowed to go forward with his appeal. “ ‘The purpose of the doctrine of equitable estoppel is to promote equity and justice in an individual case by preventing a party from asserting rights under a general rule of law when his own conduct renders the assertion of such rights contrary to equity and good conscience.’ ” Robinson v. Boohaker, Schillaci

33
First National Bank of Montgomery v. United Statesgreen
almd · 1959 · cited in 7 Alabama opinions naming this issue, 1992–2007
2 sentences

2007City of Guntersville v. Alred , 495 So.2d 566 (Ala. 1986); Alford v. City of Gadsden , supra. However, "`"[t]he doctrine of equitable estoppel is not a bar to the correction . . . of a mistake of law."'" State Highway Dep't v. Headrick Outdoor Adver., Inc. , 594 So.2d at 1205 (quoting First Nat'l Bank of Montgomery v. United States , 176 F.Supp. 768 , 772 (M.D.Ala. 1959) (quoting in turn Automobile Club of Michigan v. Commissioner , 353 U.S. 180 , 182 , 77 S.Ct. 707 , 1 L.Ed.2d 746 (1957))) (emphasis omitted).

2006However, “ ‘ “[t]he doctrine of equitable estoppel is not a bar to the correction ... of a mistake of law.” ’ ” State Highway Dep’t v. Headrick Outdoor Advertising, Inc., 594 So.2d 1202, 1205 (Ala.l992)(quoting First Nat’l Bank of Montgomery v. United States, 176 F.Supp. 768, 772 (M.D.Ala.1959), affd, 285 F.2d 123 (5th Cir.1961), quoting in turn Automobile Club of Michigan v. Commissioner, 353 U.S. 180, 182 , 77 S.Ct. 707 , 1 L.Ed.2d 746 (1957))(emphasis omitted).

27
General Elec. Credit Corp. v. Strickland Div. of Rebel Lumber Co.green
ala · 1983 · cited in 6 Alabama opinions naming this issue, 1991–2026
2 sentences

2026This court stated: " 'In order for the doctrine of equitable estoppel to apply, a party must demonstrate: " ' " '(1) That "[t]he person against whom estoppel is asserted, who usually must have knowledge of the facts, communicates something in a misleading way, either by words, conduct, or silence, with the intention that the communication will be acted on;" " ' " '(2) That "the person seeking to assert estoppel, who lacks knowledge of the facts, relies upon [the] communication;" and " ' " '(3) That "the person relying would be harmed materially if the actor is later permitted to 26 CL-2025-051

2015Draughon v. General Finance Credit Corp., 362 So.2d 880, 884 (Ala.1978).’ “Pierce v. Hand, Arendall, Bedsole, Greaves & Johnston, 678 So.2d 765, 768 (Ala.1996). ■“In order for the doctrine of equitable estoppel to apply, a party must demonstrate: ‘““(1) That ‘[t]he person against, whom estoppel is asserted, who usually must have knowledge of the facts, communicates something in a misleading way, either by words, conduct, or silence, with the intention that the communication will be acted on’; “ ‘ “(2) That ‘the person seeking to assert estoppel, who lacks knowledge of the facts, relies upon [t

26
Marsh v. Birmingham Bd. of Ed.green
ala · 1977 · cited in 6 Alabama opinions naming this issue, 1983–2013
2 sentences

2013However, ‘‘[our supreme c]ourt has held that ‘[t]he doctrine of equitable estoppel, as a general rule, is not applicable to the state, to municipal subdivisions, or to state-created agencies,’ because ‘ “[pjersons dealing with agencies of government are presumed to know the legal limitations upon their power and cannot plead estoppel on the theory that they have been misled as to the extent of that power.” ’ Marsh v. Binningham Board of Education, 349 So.2d 34, 36 (Ala.1977), quoting City of Birmingham v. Lee, 254 Ala. 237, 247 , 48 So.2d 47, 55-56 (1950).” Ex parte City of Jacksonville, 693 S

1996However, this Court has held that "[t]he doctrine of equitable estoppel, as a general rule, is not applicable to the state, to municipal subdivisions, or to state-created agencies," because " '[p]persons dealing with agencies of government are presumed to know the legal limitations upon their power and cannot plead estoppel on the theory that they have been misled as to the extent of that power.' " Marsh v. Birmingham Board of Education , 349 So.2d 34 , 36 (Ala. 1977), quoting City of Birmingham v. Lee , 254 Ala. 237 , 247 , 48 So.2d 47 , 55-56 (1950).

26
Allen v. Bennettgreen
ala · 2001 · cited in 4 Alabama opinions naming this issue, 2004–2026
2 sentences

2026This court stated: " 'In order for the doctrine of equitable estoppel to apply, a party must demonstrate: " ' " '(1) That "[t]he person against whom estoppel is asserted, who usually must have knowledge of the facts, communicates something in a misleading way, either by words, conduct, or silence, with the intention that the communication will be acted on;" " ' " '(2) That "the person seeking to assert estoppel, who lacks knowledge of the facts, relies upon [the] communication;" and " ' " '(3) That "the person relying would be harmed materially if the actor is later permitted to 26 CL-2025-051

2015Draughon v. General Finance Credit Corp., 362 So.2d 880, 884 (Ala.1978).’ “Pierce v. Hand, Arendall, Bedsole, Greaves & Johnston, 678 So.2d 765, 768 (Ala.1996). ■“In order for the doctrine of equitable estoppel to apply, a party must demonstrate: ‘““(1) That ‘[t]he person against, whom estoppel is asserted, who usually must have knowledge of the facts, communicates something in a misleading way, either by words, conduct, or silence, with the intention that the communication will be acted on’; “ ‘ “(2) That ‘the person seeking to assert estoppel, who lacks knowledge of the facts, relies upon [t

24
BSI Rentals, Inc. v. Wendtgreen
alacivapp · 2004 · cited in 3 Alabama opinions naming this issue, 2007–2026
2 sentences

2026This court stated: " 'In order for the doctrine of equitable estoppel to apply, a party must demonstrate: " ' " '(1) That "[t]he person against whom estoppel is asserted, who usually must have knowledge of the facts, communicates something in a misleading way, either by words, conduct, or silence, with the intention that the communication will be acted on;" " ' " '(2) That "the person seeking to assert estoppel, who lacks knowledge of the facts, relies upon [the] communication;" and " ' " '(3) That "the person relying would be harmed materially if the actor is later permitted to 26 CL-2025-051

2015Draughon v. General Finance Credit Corp., 362 So.2d 880, 884 (Ala.1978).’ “Pierce v. Hand, Arendall, Bedsole, Greaves & Johnston, 678 So.2d 765, 768 (Ala.1996). ■“In order for the doctrine of equitable estoppel to apply, a party must demonstrate: ‘““(1) That ‘[t]he person against, whom estoppel is asserted, who usually must have knowledge of the facts, communicates something in a misleading way, either by words, conduct, or silence, with the intention that the communication will be acted on’; “ ‘ “(2) That ‘the person seeking to assert estoppel, who lacks knowledge of the facts, relies upon [t

23
City of Birmingham v. Leegreen
ala · 1950 · cited in 2 Alabama opinions naming this issue, 1996–2013
2 sentences

2013However, ‘‘[our supreme c]ourt has held that ‘[t]he doctrine of equitable estoppel, as a general rule, is not applicable to the state, to municipal subdivisions, or to state-created agencies,’ because ‘ “[pjersons dealing with agencies of government are presumed to know the legal limitations upon their power and cannot plead estoppel on the theory that they have been misled as to the extent of that power.” ’ Marsh v. Binningham Board of Education, 349 So.2d 34, 36 (Ala.1977), quoting City of Birmingham v. Lee, 254 Ala. 237, 247 , 48 So.2d 47, 55-56 (1950).” Ex parte City of Jacksonville, 693 S

2013However, ‘‘[our supreme c]ourt has held that ‘[t]he doctrine of equitable estoppel, as a general rule, is not applicable to the state, to municipal subdivisions, or to state-created agencies,’ because ‘ “[pjersons dealing with agencies of government are presumed to know the legal limitations upon their power and cannot plead estoppel on the theory that they have been misled as to the extent of that power.” ’ Marsh v. Binningham Board of Education, 349 So.2d 34, 36 (Ala.1977), quoting City of Birmingham v. Lee, 254 Ala. 237, 247 , 48 So.2d 47, 55-56 (1950).” Ex parte City of Jacksonville, 693 S

22
State Hwy. Dept. v. HEADRICK OUTDOOR ADV.green
ala · 1992 · cited in 5 Alabama opinions naming this issue, 2001–2007
2 sentences

2007City of Guntersville v. Alred , 495 So.2d 566 (Ala. 1986); Alford v. City of Gadsden , supra. However, "`"[t]he doctrine of equitable estoppel is not a bar to the correction . . . of a mistake of law."'" State Highway Dep't v. Headrick Outdoor Adver., Inc. , 594 So.2d at 1205 (quoting First Nat'l Bank of Montgomery v. United States , 176 F.Supp. 768 , 772 (M.D.Ala. 1959) (quoting in turn Automobile Club of Michigan v. Commissioner , 353 U.S. 180 , 182 , 77 S.Ct. 707 , 1 L.Ed.2d 746 (1957))) (emphasis omitted).

2006However, “ ‘ “[t]he doctrine of equitable estoppel is not a bar to the correction ... of a mistake of law.” ’ ” State Highway Dep’t v. Headrick Outdoor Advertising, Inc., 594 So.2d 1202, 1205 (Ala.l992)(quoting First Nat’l Bank of Montgomery v. United States, 176 F.Supp. 768, 772 (M.D.Ala.1959), affd, 285 F.2d 123 (5th Cir.1961), quoting in turn Automobile Club of Michigan v. Commissioner, 353 U.S. 180, 182 , 77 S.Ct. 707 , 1 L.Ed.2d 746 (1957))(emphasis omitted).

15
Ex Parte Fieldsgreen
ala · 1983 · cited in 4 Alabama opinions naming this issue, 1992–2006
2 sentences

2006“Neither the State nor its political subdivisions ... [can] be estopped by doing that which they have no authority to do.” Ex parte Fields, 432 So.2d 1290, 1293 (Ala.1983).

2005"In Ex parte Fields , supra, at 1293 , this Court held that neither the state or its political subdivisions can be `estopped by doing that which they have no authority to do.'" The essential elements of equitable estoppel were set forth in Ledlow v. City of Pell City , 497 So.2d 86 , 89 (Ala. 1986): "`The actor, who usually must have knowledge of the true facts, communicates something in a misleading way, either by words, conduct or silence.

14
Ex Parte Napiergreen
ala · 1998 · cited in 3 Alabama opinions naming this issue, 2006–2017
2 sentences

2017In other words, "[i]f an arbitration agreement is written in broad language so that it applies to '[a]ll disputes, claims or controversies arising from or relating to this Contract or the relationships which result from this Contract ,' Ex parte Napier , 723 So.2d 49 , 51 (Ala. 1998) (emphasis added), or even in slightly narrower language so that it applies to 'ALL DISPUTES, CLAIMS OR CONTROVERSIES ARISING FROM OR RELATING TO THIS CONTRACT OR THE PARTIES THERETO ,' Stamey , 776 So.2d at 91 (capitalization in original; emphasis added), this Court will proceed to determine whether arbitration ma

2010“If an arbitration agreement is written in broad language so that it applies to ‘[a]ll disputes, claims or controversies arising from or relating to this Contract or the relationships which result from this Contract,’ Ex parte Napier, 723 So.2d 49, 51 (Ala. 1998) (emphasis added), or even in slightly narrower language so that it applies to ‘ALL DISPUTES, CLAIMS OR CONTROVERSIES ARISING FROM OR RELATING TO THIS CONTRACT OR THE PARTIES THERETO,’ Stamey, 776 So.2d at 91 (capitalization in original; emphasis added), this Court will proceed to determine whether arbitration may be compelled under th

13
Smith v. Mark Dodge, Inc.green
ala · 2006 · cited in 2 Alabama opinions naming this issue, 2009–2017
2 sentences

2017This Court has, however, crafted an exception to this equitable-estoppel exception: "Where 'the language of the arbitration provisions limited arbitration to the signing parties,' this Court has not allowed the claims against the nonsignatories to be arbitrated." Id. at 380-81 (quoting Stamey , 776 So.2d at 89 ).

2009Servs., Inc. v. Rogers, 736 So.2d 553 (Ala.1999) (holding that the language of an arbitration provision limiting the parties did not allow the application of the doctrine of equitable estoppel to compel arbitration by nonparty), and Smith v. Mark Dodge, Inc., 934 So.2d 375, 380 (Ala.2006) (noting that there is an exception to the equitable estoppel rule requiring the arbitration provision to contain sufficiently broad language indicating that the nonsig-natory was contemplated as a party).

12
Draughon v. General Fin. Credit Corp.green
ala · 1978 · cited in 2 Alabama opinions naming this issue, 1983–2015
2 sentences

2015Draughon v. General Finance Credit Corp., 362 So.2d 880, 884 (Ala.1978).’ “Pierce v. Hand, Arendall, Bedsole, Greaves & Johnston, 678 So.2d 765, 768 (Ala.1996). ■“In order for the doctrine of equitable estoppel to apply, a party must demonstrate: ‘““(1) That ‘[t]he person against, whom estoppel is asserted, who usually must have knowledge of the facts, communicates something in a misleading way, either by words, conduct, or silence, with the intention that the communication will be acted on’; “ ‘ “(2) That ‘the person seeking to assert estoppel, who lacks knowledge of the facts, relies upon [t

1983Draughon v. General Finance Credit Corporation , 362 So.2d 880 , 884 (Ala. 1978); Anders v. Sandlin , 191 Ala. 158 , 67 So. 684 (1914).

12
First Nat. Bank of Opp v. Bolesgreen
ala · 1936 · cited in 2 Alabama opinions naming this issue, 1996–2015
2 sentences

2015First National Bank of Opp v. Boles, 231 Ala. 473, 479 , 165 So. 586, 592 (1936).

2015First National Bank of Opp v. Boles, 231 Ala. 473, 479 , 165 So. 586, 592 (1936).

12
Pace v. UTILITIES BD. OF CITY OF FOLEYgreen
alacivapp · 1999 · cited in 1 Alabama opinions naming this issue, 2025–2025
11
Jack Ingram Motors, Inc. v. Wardgreen
ala · 1999 · cited in 1 Alabama opinions naming this issue, 2017–2017
11
Cook's Pest Control, Inc. v. Boykingreen
ala · 2001 · cited in 1 Alabama opinions naming this issue, 2017–2017
11
McCormack v. AmSouth Bank, NAgreen
ala · 1999 · cited in 1 Alabama opinions naming this issue, 2016–2016
11
Ex Parte City of Jacksonvillegreen
ala · 1996 · cited in 1 Alabama opinions naming this issue, 2013–2013
11
Ex Parte Ballewgreen
ala · 2000 · cited in 1 Alabama opinions naming this issue, 2007–2007
11
Robinson v. Boohaker, Schillaci Co., P.C.green
ala · 2000 · cited in 1 Alabama opinions naming this issue, 2007–2007
11
Ledlow v. City of Pell Citygreen
ala · 1986 · cited in 1 Alabama opinions naming this issue, 2005–2005
11
Thomson-Csf, S.A. v. American Arbitration Association, Evans & Sutherland Computer Corporationgreen
ca2 · 1995 · cited in 1 Alabama opinions naming this issue, 1999–1999
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 (52)

CaseCitedYears
Automobile Club of Mich. v. Commissioner green
scotus · 1957
2 sentences

2007City of Guntersville v. Alred , 495 So.2d 566 (Ala. 1986); Alford v. City of Gadsden , supra. However, "`"[t]he doctrine of equitable estoppel is not a bar to the correction . . . of a mistake of law."'" State Highway Dep't v. Headrick Outdoor Adver., Inc. , 594 So.2d at 1205 (quoting First Nat'l Bank of Montgomery v. United States , 176 F.Supp. 768 , 772 (M.D.Ala. 1959) (quoting in turn Automobile Club of Michigan v. Commissioner , 353 U.S. 180 , 182 , 77 S.Ct. 707 , 1 L.Ed.2d 746 (1957))) (emphasis omitted).

2007City of Guntersville v. Alred , 495 So.2d 566 (Ala. 1986); Alford v. City of Gadsden , supra. However, "`"[t]he doctrine of equitable estoppel is not a bar to the correction . . . of a mistake of law."'" State Highway Dep't v. Headrick Outdoor Adver., Inc. , 594 So.2d at 1205 (quoting First Nat'l Bank of Montgomery v. United States , 176 F.Supp. 768 , 772 (M.D.Ala. 1959) (quoting in turn Automobile Club of Michigan v. Commissioner , 353 U.S. 180 , 182 , 77 S.Ct. 707 , 1 L.Ed.2d 746 (1957))) (emphasis omitted).

71992–2007
Mazer v. Jackson Ins. Agency green
ala · 1976
2 sentences

2015In Mazer v. Jackson Insurance Agency, 340 So.2d 770 (Ala.1976), our supreme court discussed the doctrine of equitable estoppel, stating: “The purpose of [the doctrine of] equitable estoppel ... is to promote equity and justice in an individual case by preventing a party from asserting rights under a general technical rule of law when his own conduct renders the assertion of such rights contrary to equity and good conscience.

1999Agency , 340 So.2d 770 (Ala. 1976)." In Ex parte Four Seasons, Ltd. , 450 So.2d 110 , 111 (Ala. 1984), our supreme court stated: "Although the doctrine of equitable estoppel is, as a general rule, not applicable to the state, to municipal subdivisions, or to state-created agencies, the doctrine is applicable to the government where justice and fair play require it.

41986–2015
Ex Parte Jones green
ala · 1996
2 sentences

1999My views on when and under what circumstances the doctrine of equitable estoppel should be applied are stated in my special writings in Med Center Cars, Inc. *561 v. Smith, 727 So.2d 9 (Ala.1998) (Maddox, J., concurring in the result as to Parts I(B), II, and III; and dissenting as to Parts I(A) and I(C)); Ex parte Dickinson, 711 So.2d 984 (Ala.1998) (Maddox, J., concurring in part and dissenting in part); Ex parte Stripling, 694 So.2d 1281 (Ala.1997) (Maddox, J., concurring in part and dissenting in part); and Ex parte Jones, 686 So.2d 1166 (Ala.1996) (Maddox, J., dissenting).

1998My views on *Page 23 when and under what circumstances the doctrine of equitable estoppel should be applied are stated in my special writings in Ex parte Dickinson , 711 So.2d 984 (Ala. 1998) (Maddox, J., concurring in part and dissenting in part); Ex parte Stripling , 694 So.2d 1281 (Ala. 1997) (Maddox, J., concurring in part and dissenting in part); and Ex parte Jones , 686 So.2d 1166 (Ala. 1996) (Maddox, J., dissenting).

31998–2000
First Family Financial Services, Inc. v. Rogers green
ala · 1999
2 sentences

2009Servs., Inc. v. Rogers, 736 So.2d 553 (Ala.1999) (holding that the language of an arbitration provision limiting the parties did not allow the application of the doctrine of equitable estoppel to compel arbitration by nonparty), and Smith v. Mark Dodge, Inc., 934 So.2d 375, 380 (Ala.2006) (noting that there is an exception to the equitable estoppel rule requiring the arbitration provision to contain sufficiently broad language indicating that the nonsig-natory was contemplated as a party).

2000Servs, Inc. v. Rogers , 736 So.2d 553 (Ala. 1999); Med Center Cars, Inc. v. Smith , 727 So.2d 9 (Ala. 1998); Ex parte Isbell , 708 So.2d 571 (Ala. 1997); Ex parte Martin , 703 So.2d 883 (Ala. 1997); Ex parte Jones , 686 So.2d 1166 (Ala. 1996); Ex parte Stallings Sons, Inc. , 670 So.2d 861 (Ala. 1995); see also David F. Sawrie, Equitable Estoppel and the Outer Boundaries of Federal Arbitration Law: The Alabama Supreme Court's Retrenchment of an Expansive Federal Policy Favoring Arbitration , 51 Vand.

22000–2009
Alford v. City of Gadsden green
ala · 1977
2 sentences

2007City of Guntersville v. Alred , 495 So.2d 566 (Ala. 1986); Alford v. City of Gadsden , supra. However, "`"[t]he doctrine of equitable estoppel is not a bar to the correction . . . of a mistake of law."'" State Highway Dep't v. Headrick Outdoor Adver., Inc. , 594 So.2d at 1205 (quoting First Nat'l Bank of Montgomery v. United States , 176 F.Supp. 768 , 772 (M.D.Ala. 1959) (quoting in turn Automobile Club of Michigan v. Commissioner , 353 U.S. 180 , 182 , 77 S.Ct. 707 , 1 L.Ed.2d 746 (1957))) (emphasis omitted).

1992In Ex parte Fields , supra, at 1293 , this Court held that neither the state or its political subdivisions can be "estopped by doing that which they have no authority to do." Consequently, as this Court has held, the doctrine of estoppel may not authorize a city to do that which the city had no authority to do, Alford v. City of Gadsden , 349 So.2d 1132 (Ala. 1977); and a city may not adopt a zoning ordinance that contravenes a state law.

21992–2007
Med Center Cars, Inc. v. Smith green
ala · 1998
2 sentences

2000Servs, Inc. v. Rogers , 736 So.2d 553 (Ala. 1999); Med Center Cars, Inc. v. Smith , 727 So.2d 9 (Ala. 1998); Ex parte Isbell , 708 So.2d 571 (Ala. 1997); Ex parte Martin , 703 So.2d 883 (Ala. 1997); Ex parte Jones , 686 So.2d 1166 (Ala. 1996); Ex parte Stallings Sons, Inc. , 670 So.2d 861 (Ala. 1995); see also David F. Sawrie, Equitable Estoppel and the Outer Boundaries of Federal Arbitration Law: The Alabama Supreme Court's Retrenchment of an Expansive Federal Policy Favoring Arbitration , 51 Vand.

1999My views on when and under what circumstances the doctrine of equitable estoppel should be applied are stated in my special writings in Med Center Cars, Inc. *561 v. Smith, 727 So.2d 9 (Ala.1998) (Maddox, J., concurring in the result as to Parts I(B), II, and III; and dissenting as to Parts I(A) and I(C)); Ex parte Dickinson, 711 So.2d 984 (Ala.1998) (Maddox, J., concurring in part and dissenting in part); Ex parte Stripling, 694 So.2d 1281 (Ala.1997) (Maddox, J., concurring in part and dissenting in part); and Ex parte Jones, 686 So.2d 1166 (Ala.1996) (Maddox, J., dissenting).

21999–2000
Ex Parte Stripling green
ala · 1997
2 sentences

1999My views on when and under what circumstances the doctrine of equitable estoppel should be applied are stated in my special writings in Med Center Cars, Inc. *561 v. Smith, 727 So.2d 9 (Ala.1998) (Maddox, J., concurring in the result as to Parts I(B), II, and III; and dissenting as to Parts I(A) and I(C)); Ex parte Dickinson, 711 So.2d 984 (Ala.1998) (Maddox, J., concurring in part and dissenting in part); Ex parte Stripling, 694 So.2d 1281 (Ala.1997) (Maddox, J., concurring in part and dissenting in part); and Ex parte Jones, 686 So.2d 1166 (Ala.1996) (Maddox, J., dissenting).

1998My views on *Page 23 when and under what circumstances the doctrine of equitable estoppel should be applied are stated in my special writings in Ex parte Dickinson , 711 So.2d 984 (Ala. 1998) (Maddox, J., concurring in part and dissenting in part); Ex parte Stripling , 694 So.2d 1281 (Ala. 1997) (Maddox, J., concurring in part and dissenting in part); and Ex parte Jones , 686 So.2d 1166 (Ala. 1996) (Maddox, J., dissenting).

21998–1999
Ex Parte Dickinson green
ala · 1998
2 sentences

1999My views on when and under what circumstances the doctrine of equitable estoppel should be applied are stated in my special writings in Med Center Cars, Inc. *561 v. Smith, 727 So.2d 9 (Ala.1998) (Maddox, J., concurring in the result as to Parts I(B), II, and III; and dissenting as to Parts I(A) and I(C)); Ex parte Dickinson, 711 So.2d 984 (Ala.1998) (Maddox, J., concurring in part and dissenting in part); Ex parte Stripling, 694 So.2d 1281 (Ala.1997) (Maddox, J., concurring in part and dissenting in part); and Ex parte Jones, 686 So.2d 1166 (Ala.1996) (Maddox, J., dissenting).

1998My views on *Page 23 when and under what circumstances the doctrine of equitable estoppel should be applied are stated in my special writings in Ex parte Dickinson , 711 So.2d 984 (Ala. 1998) (Maddox, J., concurring in part and dissenting in part); Ex parte Stripling , 694 So.2d 1281 (Ala. 1997) (Maddox, J., concurring in part and dissenting in part); and Ex parte Jones , 686 So.2d 1166 (Ala. 1996) (Maddox, J., dissenting).

21998–1999
Ex Parte Four Seasons, Ltd. green
ala · 1984
2 sentences

1999Agency , 340 So.2d 770 (Ala. 1976)." In Ex parte Four Seasons, Ltd. , 450 So.2d 110 , 111 (Ala. 1984), our supreme court stated: "Although the doctrine of equitable estoppel is, as a general rule, not applicable to the state, to municipal subdivisions, or to state-created agencies, the doctrine is applicable to the government where justice and fair play require it.

1994Ex parte State Department of Human Resources; Ex parte Four Seasons, Ltd., 450 So.2d 110 (Ala.1984).

21994–1999
United States v. Lazy Fc Ranch green
ca9 · 1973
2 sentences

1989United States v. Lazy F C Ranch , 481 F.2d 985 (9th Cir. 1973).

1984United States v. Lazy F C Ranch , 481 F.2d 985 (9th Cir. 1973).

21984–1989
Auto-Plaza, Inc. v. Central Bank of Alabama green
ala · 1980
2 sentences

1989Although this Court pointed out in Auto-Plaza, Inc. v. Central Bank of Alabama, N.A. , 394 So.2d 6 (Ala. 1980), that the mere inclusion of a nonwaiver of acceleration clause does not, under all circumstances , preclude the operative effect of the doctrine of equitable estoppel, it should be noted that the agreement in Auto-Plaza did not require that any contract modifications be in writing.

1989As to the issue of equitable estoppel, our supreme court said in Auto-Plaza, Inc. v. Central Bank, 394 So.2d 6 (Ala.1980): “Ordinarily, then, the applicability vel non of the equitable estoppel doctrine is a fact issue.

21989–1989
Weil v. Hill neutral
ala · 1915
2 sentences

1947Warner v. Warner, 248 Ala. 556 , 28 So.2d 701 ; Weil v. Hill, 193 Ala. 407 , 69 So. 438 ; Alabama Great Southern R.

1947Warner v. Warner, 248 Ala. 556 , 28 So.2d 701 ; Weil v. Hill, 193 Ala. 407 , 69 So. 438 ; Alabama Great Southern R.

21946–1947
Webb v. City of Demopolis green
· 1891
2 sentences

1927Webb v. Demopolis, 95 Ala. 116 , 13 So. 289 , 21 L.

1913The doctrine is that the sovereign, in such cases, cannot be thus deprived of his rights; nor will he allow; any of his subjects, by wrongful conduct, to destroy this public right and use. —Webb v. Demopolis, 95 Ala. 116 , 13 South. 289 , 21 L.

21913–1927
Doe ex dem. McPherson v. Walters neutral
· 1849
21884–1907
Smith v. Mundy neutral
ala · 1850
2 sentences

1907Dec. 200 ; Smith v. Mundy, 18 Ala. 182 , 52 Am.

1884It has been uniformly held by this court, that “ a court of law will not look to, or consider the equity of a party, in opposition of the legal title of the other,” and that a court of equity was the only proper forum in which the purchaser of an equitable title could protect himself by invoking the doctrine of equitable estoppel. — McPherson v. Walters, 16 Ala. 714 ; Smith v. Mundy, 18 Ala. 182 ; Kelly v. Hendricks, 57 Ala. 193 ; Lehman v. Bryan, 67 Ala. 558 ; Tutwiler v. Munford, 73 Ala. 308 .

21884–1907
Boutwell v. State green
ala · 2007
12025–2025
MTA, Inc. v. Merrill Lynch, Pierce, Fenner & Smith, Inc. green
ala · 2012
12017–2017
City of Birmingham v. Cochrane Roofing & Metal Co. green
ala · 1989
12016–2016
Arkel Land Co. v. Cagle green
ala · 1983
12016–2016
Mason v. County of Mobile green
ala · 1982
12016–2016
Weaver v. Firestone green
ala · 2013
12015–2015
Joseph v. Crossing II, L.L.C. green
lactapp · 2006
12010–2010
Sparks v. Alabama Power Co. green
ala · 1996
12007–2007
City of Guntersville v. Alred green
ala · 1986
12007–2007
First National Bank of Montgomery, Estate of Georgia S. Gossler, Deceased v. United States green
ca1 · 1961
12006–2006
Ex Parte Tony's Towing, Inc. green
ala · 2002
12003–2003
Ex Parte Lovejoy green
ala · 2001
12001–2001
Ex Parte Isbell green
ala · 1997
12000–2000
Ex Parte Martin green
ala · 1997
12000–2000
Boyd v. Homes of Legend, Inc. green
almd · 1997
12000–2000
Ex Parte Stallings & Sons, Inc. green
ala · 1995
12000–2000
Ex Parte Warren green
ala · 1998
11999–1999
Maintenance, Inc. v. HOUSTON CTY. ALA. green
ala · 1983
11999–1999
Office of Personnel Management v. Richmond green
scotus · 1990
11996–1996
Durham v. Harbin green
ala · 1988
11993–1993
Galerie Des Monnaies of Geneva, Ltd. v. Deutsche Bank, A.G., New York Branch (In Re Galerie Des Monnaies of Geneva, Ltd.) green
nysb · 1985
11992–1992
Galerie Des Monnaies of Geneva, Ltd. v. Deutsche Bank, A.G. (In Re Galerie Des Monnaies of Geneva, Ltd.) green
nysd · 1986
11992–1992
TRANSAMERICA COM. FINANCE v. Union Bank green
ala · 1991
11991–1991
Anders v. Sandlin neutral
ala · 1914
11983–1983
Mooradian v. Canal Insurance Company green
ala · 1961
11966–1966

Statutes the citing opinions construe

USC § 9u.s.c.1 (8) USC § 9u.s.c.2 (7) AL § Ala. Code § 12-2-7 (5) AL § Ala. Code § 8-1-41 (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 338 (1920–2026) NY 334 (1878–2026) IL 183 (1885–2026) TX 170 (1876–2026) PA 92 (1939–2024) FL 82 (1956–2025) NJ 80 (1926–2026) AL 67 (1884–2026) NC 66 (1926–2023) WA 65 (1910–2024) CT 61 (1860–2021) TN 55 (1902–2024) ME 54 (1938–2023) MS 53 (1896–2026) MD 51 (1917–2026) OH 50 (1901–2026) NE 42 (1896–2023) MI 41 (1901–2025) WI 41 (1882–2024) LA 37 (1926–2025) RI 34 (1990–2022) MN 32 (1896–2024) IN 30 (1893–2026) MT 29 (1910–2022) NM 29 (1944–2025) CO 27 (1911–2025) MO 27 (1900–2023) ND 26 (1959–2025) UT 23 (1994–2025) OR 22 (1894–2025) GA 21 (1975–2025) VA 21 (1897–2024) ID 20 (1909–2024) VT 20 (1895–2026) KS 20 (1892–2022) HI 19 (1942–2021) AZ 19 (1900–2023) WY 18 (1891–2025) SD 17 (1942–2026) DC 17 (1975–2012) SC 17 (1903–2025) KY 16 (1923–2023) IA 16 (1911–2024) MA 15 (1900–2024) AR 14 (1922–2024) DE 14 (1966–2025) WV 13 (1918–2022) AK 12 (1906–2022) OK 9 (1924–2024) NV 9 (1980–2018) VI 2 (2017–2025) NH 2 (1992–2018)

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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