Decisions from June 27, 2025
Ex parte GBC International Bank: This case involves whether a plaintiff established personal jurisdiction over a California company doing no business in Alabama. The plaintiff wired $60,000 to a bank account maintained by GBC and owned by a third party who absconded with the money. The plaintiff sued GBC, alleging that he relied on statements on GBC’s website. The trial court denied GBC’s motion to dismiss for lack of personal jurisdiction, and GBC petitioned the Alabama Supreme Court for a writ of mandamus. A unanimous Court concluded that the plaintiff failed to establish personal jurisdiction over GBC. First, the plaintiff did not properly rebut evidence that GBC submitted in support of its motion to dismiss. Although the plaintiff submitted a purported declaration “on penalty of perjury,” that statement lacked “the date, name, or signature of a notary public” and thus could not be considered under Alabama precedent. Second, the plaintiff’s “declaration” at most showed that GBC made a general statement on its public website. The Court held that statements on that kind of “electronic billboard”—“viewable by anyone with access to the Internet”—could not subject GBC to jurisdiction in Alabama.
Ex parte Nathan Nash: This case involves the showing required to support a request to transfer a case to another county. Nash was involved in a car accident in Tuscaloosa County with a truck driven by an employee of Davis Ice Cream. Nash sued Davis Ice Cream in Jefferson County, alleging negligent training and hiring. The trial court granted Davis Ice Cream’s motion to transfer the case to Tuscaloosa County under the “interest-of-justice” prong of Alabama’s venue-change statute. A unanimous Alabama Supreme Court directed the trial court to vacate its transfer order. The Court explained that transfer under the “interest-of-justice” prong is permitted only when one county has a strong connection to the action and the other county has a weak connection. Tuscaloosa County’s only connection to the action was that it was the site of the accident; but Davis Ice Cream’s principal place of business was in Jefferson County, any negligent hiring or training would have occurred there, and Nash received treatment for his injuries in Jefferson County. The fact that an accident occurs in a county does not suffice to show that it has a strong connection to an action, and the Court therefore held that Davis Ice Cream failed to demonstrate that the interest of justice warranted a change of venue.
