Ex parte Kentucky Farm Bureau Mut. Ins. Co., , [Ms. SC-2024-0608, Mar. 21, 2025] __ So. 3d __ (Ala. 2025). In a unanimous decision, the Court (McCool, J.; Stewart, C.J., and Shaw, Wise, Bryan, Sellers, Mendheim, Mitchell, and Cook, JJ., concur) issues a writ of mandamus directing the Baldwin Circuit Court to dismiss, for lack of personal jurisdiction, a claim filed by Rebecca Henderson for uninsured motorist (“UM”) benefits against Kentucky Farm Bureau Mutual Insurance Company (“Kentucky Farm Bureau”). Henderson and her minor son were involved in an automobile collision in Alabama with Trey Allan Knapp. Henderson was insured by a Kentucky Farm Bureau policy that provided her with UM benefits. Ms. *2.
In concluding that the circuit court lacked personal jurisdiction, the Court holds that delivery of a UM policy in Kentucky does not meet the purposefully directed activity in the forum state test required for specific personal jurisdiction. Ms. **13-15. The Court reiterates that a UM insurer’s knowledge that its insured “might drive in Alabama and might suffer an automobile collision here is not sufficient to give the circuit court personal jurisdiction over it because ‘these Alabama events would not be the acts of [Kentucky] Farm Bureau but, instead, would be the unilateral [acts] of [other] person[s].’” Ms. **14-15, quoting Ex parte Georgia Farm Bureau Mutual Automobile Insurance Co., 889 So. 2d 545 (Ala. 2004), some internal quotation marks omitted.