Ex Parte Jackson Hospital & Clinic, Inc. (in Re Linda Houston v. Jackson Hospital & Clinic, Inc.)

Summary

The Alabama Supreme Court granted Jackson Hospital’s petition for a writ of mandamus, holding that the trial court’s order setting aside a summary judgment entered after the 90‑day period prescribed by Rule 59.1 was void. The Court reasoned that an oral statement by the trial judge does not satisfy the requirement that a post‑judgment motion be disposed of by a written ruling, and no consent or extension was on the record.