In 2020, Sarah E. Martin was injured in a car accident involving an 18-wheel tractor-trailer driven by Charles Streeter, an employee of Al-Amin Brothers Transportation, LLC. Martin sued the LLC, several individuals, and 18 fictitiously named defendants. In January 2023, Martin settled with the original defendants, agreeing to release them and related parties from any claims arising from the accident. Subsequently, Martin amended her complaint to add PEI Ohio, Inc. and Premium Transportation Group, Inc. (the corporations) as defendants, alleging various negligence and breach of contract claims.
The Jefferson Circuit Court enforced the settlement agreement in favor of the corporations, dismissed Martin's third amended complaint, and awarded attorney fees to the corporations. Martin filed a fourth amended complaint, which remains pending. The circuit court certified its orders as final under Rule 54(b), Ala. R. Civ. P., and Martin appealed both the enforcement of the settlement and the attorney fee award.
The Supreme Court of Alabama reviewed the case and determined that the circuit court exceeded its discretion in certifying the orders as final under Rule 54(b). The court found that the adjudicated and unadjudicated claims were closely related, the need for review might be mooted by future developments in the circuit court, and there was a possibility of having to consider the same issue again, particularly regarding attorney fees. Consequently, the Supreme Court of Alabama dismissed Martin's appeals, emphasizing the preference to avoid piecemeal litigation and the need for a final judgment on all pending claims before appellate review. View "Martin v. PEI Ohio, Inc." on Justia Law
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