Willard E. Ryals v. the Lathan Company, Inc.

Summary

The Alabama Supreme Court dismissed Willard E. Ryals’s appeal, holding that the trial court lacked subject‑matter jurisdiction to enter a judgment against Ryals and Ryals Real Estate because the amended complaint was filed after a final judgment and was not a properly commenced new action. The court affirmed that a final judgment is conclusive and cannot be altered by later amendment, rendering the trial court’s judgment void. Justice Murdock’s concurring special opinion noted a tension in the trial court’s characterization of the amendment. The decision rests on the final‑judgment rule and Rule 4(f) of the Alabama Rules of Civil Procedure.