Subject-Matter Jurisdiction - Statutory Construction


Stricklin v. Alabama Cast Iron Pipe Company, [Ms. 2190470, Dec. 18, 2020], ___ So. 3d ___ (Ala. Civ. App. 2020). The court (Edwards, J.; Thompson, P.J., and Donaldson and Hanson, JJ., concur; Moore, J., concurs in the result) reverses the Jefferson Circuit Court’s order dismissing for lack of subject-matter jurisdiction the employee’s action to set aside an agreement releasing the employer from all future workers’ compensation benefits in exchange for the employer’s release of its subrogation interest in the employee’s third-party action. The employee’s guardian argued that he lacked the mental capacity to enter the agreement.

The Court first notes that

“Jurisdiction is ‘[a] court’s power to decide a case or issue a decree.’ Black’s Law Dictionary 867 (8th ed. 2004). Subject-matter jurisdiction concerns a court’s power to decide certain types of cases. Woolf v. McGaugh, 175 Ala. 299, 303, 57 So. 754, 755 (1911) (‘ “By jurisdiction over the subject-matter is meant the nature of the cause of action and of the relief sought.” ’ (quoting Cooper v. Reynolds, 77 U.S. (10 Wall.) 308, 316, 19 L. Ed. 931 (1870))). That power is derived from the Alabama Constitution and the Alabama Code. See United States v. Cotton, 535 U.S. 625, 630-31, 122 S. Ct. 1781, 152 L. Ed. 2d 860 (2002)(subject-matter jurisdiction refers to a court’s ‘statutory or constitutional power’ to adjudicate a case).”

Ms. *8, quoting Ex parte Seymour, 946 So. 2d 536, 538 (Ala. 2006).

The court concludes the circuit court had subject-matter jurisdiction because “[e]ven if §25-5-292(b) prevents a circuit court from exercising its power to set aside a benefit-review agreement on the grounds of ‘fraud, newly discovered evidence, or other good cause” after the expiration of the 60-day period, Stricklin’s argument is not that the 2016 benefit-review agreement should be set aside for “other good cause’; instead, Stricklin’s argument is that the 2016 benefit-review agreement did not and does not exist as a legal matter because Gray lacked the requisite capacity to form mutual assent and therefore to enter a contract in the first place.” Ms *9.

The court also holds that

Although they provide that a benefit-review agreement is irrevocable after 60 days and prevent a court from setting aside a benefit-review agreement after the expiration of that 60-day period, neither §25-5-290(f)(2) nor §25-5-292(b) addresses the validity of a benefit-review agreement entered into by an incompetent or insane employee; thus, those statutes do not, as ACIPCO suggests, prevent the application of the general law declaring contracts entered into by insane or incompetent persons void. See, e.g., Baldwin Cnty. v. Jenkins, 494 So. 2d 584, 588 (Ala. 1986) (explaining that, “[w]here two statutes are related to the same subject and embrace the same matter, a specific or particular provision is controlling over a general provision.”

Ms. **11-12.

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