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Alabama Courts Must Review Substance of Claim Despite Pleading’s Title

Alabama Courts Must Review Substance of Claim Despite Pleading’s Title

by David Reutter

The Alabama Court of Civil Appeals held on August 1, 2014 that a trial court should treat pleadings according to their substance rather than their captions. Accordingly, the appellate court reversed the dismissal of a criminal action and ruled the matter should have been treated as a civil case based upon the facts and requested relief in the petition.

In January 2014, Donaldson Correctional Facility prisoner Gregory J. Eddins, 46, who is serving a 30-year sentence, submitted a court filing entitled “Petition for Relief from Conviction or Sentence.”

The verified petition alleged a September 2010 laboratory test indicated Eddins had diabetes. Yet he was not being treated for that disease, putting him at “risk of going blind, losing a limb, going into diabetic coma, or dying.” Among the relief requested, Eddins asked state officials to “provide him with necessary or appropriate medical care to treat his diabetes.”

The trial court dismissed the action because the remedy he sought was not available through a Rule 32 petition, which is the mechanism to challenge a criminal conviction or sentence. Eddins appealed to the Alabama Court of Criminal Appeals, which transferred the case to the Court of Civil Appeals.

That appellate court said that while Eddins’ appellate brief was “not a model of clarity,” it was clear he alleged his constitutional rights were being violated by the improper withholding of medical care. The court noted that “[i]t has long been the law that nomenclature” – the name or term used – “is not the determining factor regarding the nature of the party’s pleadings or motions.”

Eddins, the Court of Civil Appeals held, had stated a claim for which relief could be granted; thus, it was error for the trial court to dismiss his petition. While expressing no opinion as to the substantive merits of Eddins’ claim, the appellate court reversed and remanded the case for further proceedings. See: Eddins v. Alabama, 160 So.3d 18 (Ala. Civ. App. 2014).


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Related legal case

Eddins v. Alabama