Walter Energy, Inc. v. Audley Capital Advisors LLP

Summary

The Supreme Court of Alabama affirmed the Jefferson Circuit Court’s dismissal of Walter Energy’s claims under the Alabama Securities Act and its intentional interference claim, finding the complaint insufficient under Rule 12(b)(6). The Court held that the securities‑act claim failed to allege that offers were made and received in Alabama, and that the defendants were not strangers to the alleged business relationships, precluding liability for interference. The decision rests on a de novo review of the pleadings and established standards for pleading and the stranger requirement.