Laura Miller v. City of Birmingham

Summary

The court held that Unum was neither an indispensable party nor a jointly liable party, and that its absence did not deprive the circuit court of subject-matter jurisdiction. It further held that factual questions remained concerning when Miller discovered or should have discovered the alleged misrepresentation, so the limitations defenses did not support summary judgment. The court affirmed only the City's immunity from wanton and reckless-misrepresentation claims, reversed the judgment in all other respects, and remanded.