Jefferson County Board of Health v. Birmingham Hide & Tallow Co.

Summary

The Supreme Court of Alabama held that the trial court exceeded its discretion by granting Birmingham Hide & Tallow relief from a consent judgment without the company alleging or proving a valid ground under Rule 60(b), Ala. R. Civ. P. The court concluded that the judgment was not void and that extraordinary relief under Rule 60(b)(6) was unavailable because the company had agreed to the liquidated-damages provision and waited more than a year to challenge it. The judgment was reversed and the case remanded.

Holdings

1. A party seeking relief from a final judgment under Rule 60(b) must allege and prove one of the rule's specified grounds; because BHT's motion cited no applicable subsection and offered no evidence establishing a Rule 60(b) ground, the trial court exceeded its discretion by granting relief.
2. A judgment is void under Rule 60(b)(4) only when the rendering court lacked subject-matter or personal jurisdiction or acted inconsistently with due process; the judgment here was not void because the trial court had jurisdiction and BHT received due process.
3. Rule 60(b)(6) relief is available only in extraordinary and compelling circumstances, and it is unavailable to a party that failed to do everything reasonably within its power to obtain a favorable result before the judgment became final.

Questions Presented

1. Whether BHT established a permissible ground under Rule 60(b), Ala. R. Civ. P., for relief from the final consent judgment.
2. Whether the judgment or its liquidated-damages provision was void under Rule 60(b)(4) because of lack of jurisdiction or denial of due process.
3. Whether extraordinary and compelling circumstances supported relief under Rule 60(b)(6) despite BHT's failure to challenge the provision before the judgment became final.

Disposition

reversed_and_remanded