Miguel A. Laborde and Himelda Johanna Cruz-Candelo v. Citizens Bank, N.A.

Summary

The Alabama Supreme Court affirmed the trial court's dismissal of the claim for breach of the implied covenant of good faith and fair dealing, but reversed the dismissals of the breach‑of‑contract, wrongful‑foreclosure, and unjust‑enrichment claims, remanding for further proceedings. The Court held that the good‑faith claim is not an independent cause of action, while the other three claims were sufficiently pleaded under Alabama law.