Progress Industries, Inc. v. Dexter K. Wilson and Denise Wilson.

Summary

The Supreme Court of Alabama reversed the trial court’s default judgment against Progress Industries, Inc. and remanded because the corporation’s letter filed with the court constituted an appearance under Rule 55(b)(2), triggering the three‑day notice requirement; the appeal was therefore timely. Justice Lyons filed a specially‑concurring opinion agreeing with the majority’s conclusion on the appearance issue.