Wachovia Bank, N.a., and American Casualty Company v. Jones, Morrison & Womack, P.c.

Summary

The Alabama Supreme Court held that the Alabama Legal Services Liability Act applies to the out‑of‑state law firm, affirmed the judgment as a matter of law that expert testimony was required for the claim concerning the sworn statement of account, and reversed the judgment as a matter of law for the claims that the lawyers failed to close the file and that the firm caused service by publication, finding expert testimony unnecessary for those claims. Justice BOLIN concurred in part and dissented in part, agreeing with the majority except on the expert‑testimony requirement for the sworn‑statement claim and arguing expert testimony is also needed for the service‑by‑publication claim.