Ex Parte American Cast Iron Pipe Company; In re: Stricklin

Supreme Court of Alabama

Jefferson County | No. 1200500 | Sept. 23, 2022


In this case, Stricklin, acting as guardian for Gray, contested a 2016 benefit-review agreement between Gray and ACIPCO on the grounds that Gray was mentally incompetent at the time he signed it. Gray had sustained a serious head injury in 2014 while working for ACIPCO, and in 2016, he released ACIPCO from liability in exchange for workers' compensation benefits. Stricklin argued that due to Gray's incompetency, the agreement was void from the start, and the 60-day review period stipulated in § 25-5-292(b) did not apply. ACIPCO countered by claiming that the stipulated 60-day review period had already expired, and so the court lacked jurisdiction.

The trial court dismissed Stricklin's complaint due to the lapse of the 60-day period, but this decision was reversed by the Court of Civil Appeals, which held that the agreement was potentially legally nonexistent due to Gray’s inability to form mutual assent, mandating a trial court review of Stricklin’s claim. ACIPCO sought a certiorari review, questioning the applicability of § 8-1-170 to benefit-review agreements and the interpretation of the 60-day rule in § 25-5-292(b). The essence of the legal discourse revolves around the interpretation of legal statutes, the foundational principles of contract formation—including mental competency—and the construction of the specific legislative text. The conclusion sees Stricklin’s appeal as justified due to the absence of explicit legislative stipulation negating the applicability of § 8-1-170 or identifying mental incapacity within the 60-day rule of § 25-5-292(b).

Other Decisions Regarding Similar Topics:

-Navigation-
-Contact-
  • Phone: (205) 335-4190
  • Fax: (205) 278-5875
  • Email: thompsonfirm.al.law@gmail.com