plain and palpable error (Alabama) · Go Syfert
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plain and palpable error in Alabama

52 Alabama opinions name it 2 courts 1983–2026 7 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 (8)

CaseFollowedCited
Allstate Ins. Co. v. Skeltongreen
ala · 1996 · cited in 44 Alabama opinions naming this issue, 2003–2026
2 sentences

2026Co. v. Skelton, 675 So. 2d 377, 379 (Ala. 1996).

2003In Allstate Insurance Co. v. Skelton , 675 So.2d 377 (Ala. 1996), this Court stated: "When a judge in a nonjury case hears oral testimony, a judgment based on findings of fact based on that testimony will be presumed correct and will not be disturbed on appeal except for a plain and palpable error.

3344
Smith v. Ann Muchiagreen
ala · 2003 · cited in 37 Alabama opinions naming this issue, 2006–2025
2 sentences

2025Our ore tenus standard of review is well settled. " 'When a judge in a nonjury case hears oral testimony, a judgment based on findings of fact based on that testimony will be presumed correct and will not be disturbed on appeal except for a plain and palpable error.' " Smith v. Muchia, 854 So. 2d 85, 92 (Ala. 2003) (quoting Allstate Ins.

2025Because Haag had had notice that Wilson was building on his property and had done nothing about it, the court ruled in favor of the plaintiffs, granting them "a permanent constructive/implied easement as to all existing encroachments." Haag appealed the circuit court's decision. 1 III. 1" ' " When a judge in a nonjury case hears oral testimony, a judgment based on findings of fact based on that testimony will be presumed correct and will not be disturbed on appeal except for a plain and palpable error." ' " Yeager v. Lucy, 998 So. 2d 460, 462 (Ala. 2008) (quoting Smith v. Muchia, 854 So. 2d 85

2837
Hall v. Mazzonegreen
ala · 1986 · cited in 21 Alabama opinions naming this issue, 2008–2025
2 sentences

2025Co. v. Skelton, 675 So. 2d 377, 379 (Ala. 1996)). " ' " 'The ore tenus rule is grounded upon the principle that when the trial court hears oral testimony it has an opportunity to evaluate the demeanor and credibility of witnesses.' Hall v. Mazzone, 486 So. 2d 408, 410 (Ala. 1986).

2024Co. v. Skelton, 675 So. 2d 377, 379 (Ala. 1996)). " ' " 'The ore tenus rule is grounded upon the principle that when the trial court hears oral testimony it has an opportunity to evaluate the demeanor and credibility of witnesses.' Hall v. Mazzone, 486 So. 2d 408, 410 (Ala. 1986).

1721
First Nat. Bank of Mobile v. Duckworthgreen
ala · 1987 · cited in 11 Alabama opinions naming this issue, 1995–2013
2 sentences

2013Griggs v. Driftwood Landing, Inc., 620 So.2d 582 (Ala.1993); First National Bank of Mobile v. Duckworth, 502 So.2d 709 (Ala.1987).

2013Co. v. Skelton, 675 So.2d 377, 379 (Ala.1996)); see also First Nat’l Bank of Mobile v. Duckworth, 502 So.2d 709 (Ala.1987).

711
Kennedy v. Boles Investments, Inc.green
ala · 2010 · cited in 3 Alabama opinions naming this issue, 2016–2023
2 sentences

2023Standard of Review " ' "When a judge in a nonjury case hears oral testimony, a judgment based on findings of fact based on that testimony will be presumed correct and will not be disturbed on appeal except for a plain and palpable error." ' " Kennedy v. Boles Invs., Inc., 53 So. 3d 60, 67-68 (Ala. 2010) 4 SC-2022-0821 (citations omitted).

2016Ordinarily, “ “[w]hen a judge in a nonjury case hears oral testimony, a judgment based on findings of fact based on that testimony will be presumed correct and will not be disturbed on appeal except for a plain and palpable error.” ’ ” Kennedy v. Boles Invs., Inc., 53 So.3d 60, 67-68 (Ala.2010) (quoting Smith v. Muchia, 854 So.2d 85, 92 (Ala.2003), quoting in turn Allstate Ins.

33
Yeager v. Lucygreen
ala · 2008 · cited in 1 Alabama opinions naming this issue, 2025–2025
1 sentence

2025Because Haag had had notice that Wilson was building on his property and had done nothing about it, the court ruled in favor of the plaintiffs, granting them "a permanent constructive/implied easement as to all existing encroachments." Haag appealed the circuit court's decision. 1 III. 1" ' " When a judge in a nonjury case hears oral testimony, a judgment based on findings of fact based on that testimony will be presumed correct and will not be disturbed on appeal except for a plain and palpable error." ' " Yeager v. Lucy, 998 So. 2d 460, 462 (Ala. 2008) (quoting Smith v. Muchia, 854 So. 2d 85

11
Shewmake v. Estate of Shewmakegreen
ala · 2006 · cited in 1 Alabama opinions naming this issue, 2012–2012
1 sentence

2012See also Shewmake v. Estate of Shewmalce, 940 So.2d 260, 264 (AIa.2006). 4 “The evidence in this case was presented to the trial judge in a bench trial. ‘ “When a judge in a nonjury case hears oral testimony, a judgment based on findings of fact based on that testimony will be presumed correct and will not be disturbed on appeal except for a plain and palpable error.” ’ Smith v. Muchia, 854 So.2d 85, 92 (Ala.2003) (quoting Allstate his.

11
Ex Parte Board of Zoning Adjustmentgreen
ala · 1994 · cited in 1 Alabama opinions naming this issue, 2007–2007
2 sentences

2007Co. v. Skelton , 675 So.2d 377 , 379 (Ala. 1996). "[H]owever, that presumption has no application when the trial court is shown to have improperly applied the law to the facts." Ex parte Board of Zoning Adjustment of Mobile , 636 So.2d 415 , 417 (Ala. 1994).

2007Co. v. Skelton, 675 So.2d 377, 379 (Ala.1996). "[H]owever, that presumption has no application when the trial court is shown to have improperly applied the law to the facts." Ex parte Board of Zoning Adjustment of Mobile, 636 So.2d 415, 417 (Ala. 1994).

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 (5)

CaseCitedYears
Griggs v. Driftwood Landing, Inc. green
ala · 1993
2 sentences

2013Griggs v. Driftwood Landing, Inc., 620 So.2d 582 (Ala.1993); First National Bank of Mobile v. Duckworth, 502 So.2d 709 (Ala.1987).

2003Griggs v. Driftwood Landing, Inc. , 620 So.2d 582 (Ala. 1993); First National Bank of Mobile v. Duckworth , 502 So.2d 709 (Ala. 1987).

41995–2013
Wallace v. JEFFERSON CTY. DEPT. OF PENSIONS & SECURITY green
alacivapp · 1987
1 sentence

1991Wallace v. Jefferson County Dep’t of Pensions & Sec., 501 So.2d 473 (Ala.Civ.App.1986), cert. quashed, (Ala.1987).

11991–1991
General Motors Corp. v. Edwards green
ala · 1985
1 sentence

1991We presume that a trial court’s ruling on the issue of damages is correct and we will not disturb such a ruling unless we find it to be a plain and palpable error.” In Alabama Farm Bureau, three Justices dissented because this Court failed to address the excessiveness issue, just as three Justices had dissented when a plurality of this Court had refused to address the issue of the trial court’s remittitur in General Motors Corp. v. Edwards, supra. Two Justices were recused in Alabama Farm Bureau, just as two Justices were recused in General Motors Corp. v. Edwards.

11991–1991
Vest v. Gay green
ala · 1963
2 sentences

1986Vest v. Gay, 275 Ala. 286 , 154 So.2d 297 (1963).

1986Vest v. Gay, 275 Ala. 286 , 154 So.2d 297 (1963).

11986–1986
Fields v. Parker green
ala · 1978
2 sentences

1983Upon examination of the entire record, and granting the presumption to which its action is entitled, it cannot be stated that the trial court's denial of a new trial conditioned on a remittitur of $1,983,869 was a plain and palpable error and manifest abuse of discretion, "regardless of [this Court's] beliefs regarding any sum to which the plaintiff might have been entitled." Fields v. Parker, supra, 361 So.2d at 361 .

1983Upon examination of the entire record, and granting the presumption to which its action is entitled, it cannot be stated that the trial court's denial of a new trial conditioned on a remittitur of $1,983,869 was a plain and palpable error and manifest abuse of discretion, "regardless of [this Court's] beliefs regarding any sum to which the plaintiff might have been entitled." Fields v. Parker, supra , 361 So.2d at 361 .

11983–1983

Statutes the citing opinions construe

AL § Ala. Code § 12-2-7 (7)

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

AL 52 (1983–2026) PA 6 (1917–2015) NV 4 (1992–2002) KS 2 (1900–1928)

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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