Supreme Court of Alabama
Eric Jackson v. State Farm Mutual Automobile Insurance Company
June 20, 2025
Summary
The Supreme Court of Alabama affirmed judgment on the pleadings for State Farm, holding that the parties' Kentucky choice-of-law agreement expressly incorporated Kentucky's two-year limitations period for accident-related claims into the UIM policies. Because Jackson filed his UIM action after that period expired, the contractual limitation was enforceable and barred his claim. The court distinguished Alabama authority involving contracts without an express choice-of-law provision or specific incorporation of a foreign limitations period.