Alabama Mutual Insurance Corporation v. City of Vernon (city of Fairfield)

Summary

The court first remanded to allow substitution of a new class representative after the original representative settled and withdrew. On return to remand, it held that the dispute challenged insurance forms and rates approved by the Insurance Commissioner, making the filed-rate doctrine applicable and requiring exhaustion of administrative remedies before judicial review. The court therefore vacated the class-certification order and dismissed the appeal for lack of subject-matter jurisdiction. Moore, Chief Justice, dissenting, would have held that the circuit court had jurisdiction because the action challenged the legality of an exclusion and sought relief unavailable through administrative proceedings.