Terry v. Randolph, No. CL-2025-0972, 2026 WL 2450915, (Ala. Civ. App. Aug. 21, 2026). The Alabama Court of Civil Appeals (per curiam; all Judges concur) dismisses the appeal with instructions, holding that the Marion Circuit Court lacked subject-matter jurisdiction to enforce terms of an alleged settlement agreement that were not incorporated into its final judgment. Id. at *4–5. The court explains that, after the time for post-judgment relief expires, a trial court retains only residual jurisdiction to interpret and enforce its final judgment and cannot exercise jurisdiction over matters merely related to that judgment. See Ex parte Caremark Rx, LLC, 229 So. 3d 751, 757, 760 (Ala. 2017). Id. at *4. Because the final judgment did not incorporate the alleged settlement term requiring the Terrys to sell the table, enforcement of that term requires a new breach-of-contract action rather than a motion to enforce the prior judgment. See Lem Harris Rainwater Fam. Tr. v. Rainwater, 373 So. 3d 1089, 1093–94 (Ala. 2022); City of Orange Beach v. Lamar Cos., 403 So. 3d 832 (Ala. 2024). Id. at *4. The circuit court’s order enforcing the alleged settlement agreement was therefore void, and, because a void order will not support an appeal, the court dismisses the appeal with instructions for the circuit court to vacate its August 26, 2025 order. Id. at *4–5.
