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Howard v. Ryder Truck Rental One-Way, Inc.

Citations: 624 So. 2d 169; 1993 Ala. LEXIS 665; 1993 WL 262041Docket: 1920539

Court: Supreme Court of Alabama; July 16, 1993; Alabama; State Supreme Court

Narrative Opinion Summary

In this case, the plaintiff sought to recover damages from the defendants following a motor vehicle accident that occurred on August 28, 1984. Initially, the plaintiff filed suit in New York on September 18, 1986, within New York's three-year statute of limitations, but after Alabama's two-year statute had expired. A stipulation was entered on May 7, 1987, allowing for the discontinuance of the New York action with an agreement to waive the statute of limitations defense if the case were transferred to Alabama. However, the plaintiff failed to act on the stipulation, resulting in no formal dismissal of the New York action. Subsequently, the plaintiff filed a lawsuit in Alabama on May 29, 1992, nearly eight years post-accident, and an extensive delay of five years following the stipulation. The court found the stipulation unenforceable due to its indefinite nature and the plaintiff's inaction, resulting in an unreasonable delay that surpassed both states' statutes of limitations with no justification. Consequently, the court granted summary judgment for the defendants, and the decision was upheld by the appellate court, with costs imposed on the plaintiff.

Legal Issues Addressed

Enforceability of Stipulation Agreements

Application: The stipulation agreement to waive the statute of limitations defense was deemed unenforceable due to its lack of definite terms and the plaintiff's failure to execute the discontinuance of the New York action.

Reasoning: The court concluded that the May 7, 1987, stipulation was unenforceable as it was merely an agreement to agree in the future, lacking definite terms.

Statute of Limitations under New York and Alabama Law

Application: The court found that the plaintiff's filing in Alabama was untimely as it exceeded both New York's and Alabama's statutes of limitations without any exceptional circumstances.

Reasoning: The plaintiff filed a lawsuit in Alabama on May 29, 1992, nearly eight years after the accident, with a five-year gap since the stipulation, during which no actions were taken by the plaintiff.

Summary Judgment Standards

Application: The court granted summary judgment in favor of the defendants, concluding there were no material issues of law or fact due to the plaintiff's unreasonable delay and failure to meet procedural requirements.

Reasoning: Consequently, the court found no material issues of law or fact remaining and granted judgment in favor of the defendants, with costs taxed to the plaintiff.