Black Warrior Electric Membership Corporation v. Ronald McCarter

Summary

The Alabama Supreme Court reversed the trial court’s judgment for McCarter, holding that Black Warrior Electric did not present substantial evidence of actual or constructive notice that its power line was defectively low, and therefore the jury’s verdict was unsupported. The Court also ruled that the doctrine of res ipsa loquitur does not apply to relieve the plaintiff of the notice burden. The decision was reviewed de novo under the summary‑judgment standard and the case was remanded for entry of a judgment in Black Warrior’s favor.