Jackson v. State Farm Mut. Auto. Ins. Co.

• Docket Number: SC-2024-0588
• Decision Date: 20 June 2025
• Citation: Jackson v. State Farm Mut. Auto. Ins. Co., SC-2024-0588 (Ala. Jun 20, 2025)
• Parties: Eric Jackson v. State Farm Mutual Automobile Insurance Company
• Court: Alabama Supreme Court

1

Eric Jackson v. State Farm Mutual Automobile Insurance Company

No. SC-2024-0588

Supreme Court of Alabama

June 20, 2025

Appeal from Morgan Circuit Court(CV-22-900105)

SHAW JUSTICE.

Eric Jackson, a plaintiff below, appeals from the Morgan Circuit Court's judgment on the pleadings disposing of his claim seeking to recover uninsured/underinsured-motorist ("UIM") benefits from his insurer, State Farm Mutual Automobile Insurance Company("State Farm").We affirm.

Facts and Procedural History

Jackson a commercial tractor-trailer driver, was, on December 20 2020, injured in a motor-vehicle collision with another tractor-trailer in Morgan County.At all relevant times Jackson's personal vehicles were insured by State Farm.His policies, which were issued in Kentucky and delivered to Jackson at the Kentucky residential address he provided to State Farm, included UIM coverage.

In April 2022, Jackson sued, among others, the alleged at-fault driver in the collision ("the tortfeasor") in the Morgan Circuit Court("the trial court").^[1] On October 27, 2023, Jackson filed a motion seeking leave from the trial court to amend his original complaint to add State Farm as a defendant.More specifically, Jackson sought to recover UIM benefits under his State Farm policies.In support of his request, Jackson explained:

"... [Jackson] was recently offered the limits of available insurance from all of the tortfeasors in the original complaint.Following this offer, [Jackson] made a claim for [UIM] benefits on his personal auto insurance with [State] Farm.

". In response to this claim, [Jackson] was informed that [State] Farm is asserting the statute of limitations of the State of Kentucky in violation of longstanding Alabama law and has denied the claim."

In its answer to Jackson's amended complaint, to which it attached verified copies of Jackson's insurance policies, State Farm conceded the facts of Jackson's accident and his entitlement to UIM coverage under the policies, but "only if and to the extent [he] . satisfied all the terms and conditions of the Kentucky policies providing [him] UIM coverage, including the submission of a valid and timely claim for UIM benefits as prescribed by governing Kentucky law."It further explained: "The Kentucky General Assembly, as part of its Motor Vehicle Reparations Act which also provides for UIM coverage, has adopted a two-year 'period of time required by Kentucky law for filing a lawsuit to recover bodily injury damages incurred as a result of a motor vehicle accident.'"

According to State Farm, Jackson had failed to comply with a condition precedent to his recovery of UIM benefits.More specifically, it maintained, Jackson had failed to assert his UIM claim within the two-year period stated in his policies.The policies provided, on that issue, the following:

"Legal action may not be brought against [State Farm] until there has been full compliance with all the provisions of this policy.In addition, legal action may only be brought against [State Farm] regarding:

''....

"d.[UIM] coverage if such action is commenced within the period of time required by Kentucky law for filing a lawsuit to recover bodily injury damages incurred as a result of a motor vehicle accident."

(Some emphasis added.)As discussed in more detail below, the emphasized portion of the policy language is a direct reference to the Kentucky Motor Vehicle Reparations Act ("the KMVRA"), Ky. Rev. Stat. Ann. § 304.39-230(6).The policies further included, on that same page, a "Choice of Law" provision indicating, in all relevant circumstances, that, "[w]ithout regard to choice of law rules, the law of the state of ... Kentucky will control."(Capitalization in original.)

Accordingly, State Farm's answer also gave notice pursuant to Rule 44.1, Ala. R. Civ. P., of its intent "'to raise an issue concerning the law of another state,' specifically ... Kentucky," because, it said, Kentucky law controlled the interpretation and application of Jackson's policies.It also included citations to several cases in which, State Farm asserted, Alabama's appellate courts have routinely applied the law of the state where a policy issued to determine an insured's entitlement to UIM benefits.Based on the foregoing, and contrary to the allegations in Jackson's amended complaint, State Farm's answer asserted that Jackson was not entitled to recover UIM benefits based on his failure to timely assert his UIM claim within the two-year period that, it argued, was specified by Kentucky law and by his policies.

At the same time, State Farm separately filed, pursuant to Rule 12(c), Ala. R. Civ. P., a motion seeking the entry of a judgment on the pleadings in its favor on the same basis, namely Kentucky's purported adoption of a two-year statutory period for filing a lawsuit to recover bodily injury damages resulting from a motor-vehicle accident, seeKy. Rev. Stat. Ann. § 304.39-230(6);State Farm's incorporation of that limitations period in its policy language; and Jackson's failure to commence his UIM action against State Farm until well after the period applicable to his own claim had expired in December 2022.

Although he did not dispute the status of Kentucky law as asserted by State Farm, Jackson, in opposition to State Farm's motion, provided authority suggesting that the procedural law of the forum state supplies the applicable statute of limitations and that, under § 6-2-34,Ala. Code 1975, a six-year limitations period applied, thus rendering his UIM claim timely under Alabama law.He further argued that § 6-2-15,Ala. Code 1975, codifies long-standing public policy and, accordingly, "voids any contract provision that seeks to shorten this six-year statute."

While State Farm's motion remained pending, Jackson filed, on April 10, 2024, a "Pro Tanto Stipulation of Dismissal" to dismiss the tortfeasor and the tortfeasor's employer as defendants in the underlying action.

After further filings from the parties regarding State Farm's Rule 12(c) motion and a hearing, the trial court rejected Jackson's position and dismissed State Farm as a defendant by a judgment granting State Farm's motion and stating as follows: "The Court finds that [Jackson] is not entitled to UIM benefits in accordance with the contract entered into between [Jackson] and State Farm.This Court believes that the law of Kentucky govern[s] the claim and as such, [Jackson] did not timely file [his] complaint."The trial court, at the request of the parties, later amended its judgment to certify it as final pursuant to Rule 54(b), Ala. R. Civ. P. Jackson appeals.

Standard of Review

Rule 12(c) provides, in pertinent part: "After the pleadings are closed but within such time as not to delay the trial, any party may move for judgment on the pleadings."

"When a motion for judgment on the pleadings is made by a party, 'the trial court reviews the pleadings filed in the case and, if the pleadings show that no genuine issue of material fact is presented, the trial court will enter a judgment for the party entitled to a judgment according to the law.'B.K.W. Enters., Inc. v. Tractor &Equip. Co., 603 So.2d 989, 991(Ala.1992).See alsoDeaton, Inc. v. Monroe, 762 So.2d 840(Ala.2000).A judgment on the pleadings is subject to a de novo review.Harden v. Ritter, 710 So.2d 1254, 1255(Ala. Civ. App.1997).A court reviewing a judgment on the pleadings accepts the facts stated in the complaint as true and views them in the light most favorable to the nonmoving party.Id. at 1255-56."

Universal Underwriters Ins. Co. v. Thompson, 776 So.2d 81, 82-83(Ala.2000).

Discussion

I.

The parties represent, as they conceded during the hearing below that Jackson's appeal presents the narrow question whether a contractual provision that shortens the statutory limitations period otherwise prescribed by Alabama law may be enforced.For several reasons, Jackson contends that it may not.

Jackson cites § 6-2-15, which provides: "Except as may be otherwise provided by the Uniform Commercial Code, any agreement or stipulation, verbal or written, whereby the time for the commencement of any action is limited to a time less than that prescribed by law for the commencement of such action is void."He further argues that this Court's decision in Galliher v. State Mutual Life Insurance Co., 150 Ala. 543, 43 So. 833(1907), controls the outcome of this appeal, and he relies on recent decisions issued by United States District Courts located in Alabama which, he asserts, resolve the issue in his favor.See, e.g., AFC Franchising, LLC v. Fabbro, No. 2:18-cv-00743-AKK, Dec. 6, 2019(N.D. Ala. 2019)(not reported in Federal Supplement)(deciding, when faced with Maryland law, which the parties agreed would govern the contract, that a contractual provision shortening the applicable Alabama limitations period was void under Galliherand§ 6-2-15).In essence, according to Jackson, although Kentucky law permits the shortening of a statutory limitations period by contract, Alabama law and public policy do not and, instead, specifically void any attempt to do so.Jackson also argues that the trial court erred in dismissing State Farm as a defendant because, he contends, our caselaw provides that Alabama procedural laws -- including our statutes of limitations -- "are ... applied to matters brought in Alabama Courts, even when the contract at issue contains a provision seeking to shorten the statute of limitations."Jackson's briefat p. 2.See also, e.g., Etheredge v. Genie Indus., Inc., 632 So.2d 1324, 1326(Ala.1994)("'[A]court will apply foreign law only to the extent that it deals with the substance of the case, i.e., affects the outcome of the litigation, but will rely...