Henry Penick v. Most Worshipful Prince Hall Grand Lodge F & a M of Alabama, Inc.

Summary

The Alabama Supreme Court affirmed the trial court’s summary‑judgment on the deed‑in‑lieu and standing issues, reversed the judgment on the ejectment count, and remanded for further proceedings. The Court held that the Lodge has standing and capacity to sue, that the modification agreement expressly authorizes a deed‑in‑lieu upon written demand, and that the complaint’s specificity was sufficient. Justice Murdock filed a concurring opinion agreeing with the majority’s holdings while emphasizing the burden‑shifting under Rule 9(a).