Angela Taylor initiated a lawsuit against Hibbett Sporting Goods, Inc. ("Hibbett") in February 2017. Taylor sought benefits under the Alabama Workers' Compensation Act, contending she sustained injuries during her employment. Additionally, she sought damages for retaliatory discharge. Hibbett requested a dismissal, indicating that Taylor's actual employer was Hibbett Wholesale, Inc., a separate entity. The trial court consequently mandated Taylor to amend her complaint within 21 days, specifying her actual employer. Taylor failed to make the required amendments, leading to the trial court's dismissal of her complaint by July 31, 2017.
In a subsequent development, Taylor presented a postjudgment motion on August 31, 2017, challenging the dismissal. The trial court, after a hearing, denied the motion on November 6, 2017. On December 18, 2017, Taylor submitted her appeal, which was later transferred between courts due to jurisdictional issues.
Hibbett highlighted a crucial issue in its appellate brief. Taylor's postjudgment motion, filed on August 31, was submitted more than 30 days after the trial court's dismissal. Although Taylor argued technical difficulties with the electronic-filing system, her submission did not adhere to the stipulated timing requirements of the electronic-filing policy manual. Taylor's motion and declaration were filed at 5:24 p.m., past the prescribed noon deadline.
An untimely postjudgment motion doesn't extend the appeal period. Taylor's appeal, filed in December, exceeded the 42-day limit post the trial court's judgment. Hence, Taylor's appeal was deemed untimely, resulting in its dismissal.
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