Final Judgment not Subject to Revision Absent a Timely Post-Judgment is Filed

The Alabama High School Athletic Association, et al. v. W.T.K., etc., et al., [Ms. CL-2025-0743, Nov. 7, 2025] __ So. 3d __ (Ala. Civ. App. 2025). The court (Fridy, J.; Moore, P.J., and Hanson and Bowden, JJ., concur; Edwards, J., concurs in the result) dismisses the Alabama High School Athletic Association (“the AHSAA”) and its executive director Heath Harmon’s appeal from the Montgomery Circuit Court’s judgment permanently enjoining them from imposing sanctions against a high-school football player and a year’s probation against Marbury High School. The judgment was final. The trial court lacked subject-matter jurisdiction because the trial court had dismissed the lawsuit before Marbury High School and the player filed their show-cause motions that led to the issuance of the permanent injunction.

The court explains

The trial court dismissed the player’s action against the AHSAA defendants in its judgment of October 30, 2024, and explicitly declared that the judgment was final. No party filed a postjudgment motion in the case, and the player did not appeal from that judgment. Neither Marbury High School, which was not a party in the original action, nor the player filed their show-cause motions until three months after the entry of the judgment dismissing that action. In Faith Properties, LLC v. First Commercial Bank, 988 So. 2d 485, 490 (Ala. 2008), our supreme court observed that “‘it is well settled that ‘a judgment is not subject to revision after all the claims of all parties have been adjudicated, absent a timely motion filed pursuant to Rules 55, 59, or 60, Ala. R. Civ. P.’”

Ms. *8.

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