Walker v. Capstone Building Corp.
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At issue in this case was the application of a six-year statute of limitations to a claim of "wantonness." Plaintiff William Walker filed suit against Capstone Building Corporation (Capstone) and several fictitiously named parties. Capstone had been the general contractor on a construction job on which he worked. While working at the construction site, Plaintiff stepped onto a manhole cover which flipped over, causing him to fall into the hole. Plaintiff asserted that Capstone had been responsible for providing a safe work environment at the site, but it failed to do so. Plaintiff alleged that Capstone's failure to secure the manhole cover constituted "negligence" or "wantonness." Alabama law provides that wanton conduct must be commenced within six years. Capstone moved to dismiss the claims, asking the Supreme Court to change Alabama case law in favor of a two-year limitation for this case. The Supreme Court engaged in an extensive review of the trial record and the applicable law. The Court overruled its previous holding in "McKenzie v. Killian" which mandated the six-year limitation on claims for wantonness, finding that if it "did not ... overrule 'McKenzie,' [the Court] would be enshrining in out law an erroneous decision." The Court found that "the law in Alabama concerning the proper legal analysis of wantonness was not settled and was in fact based on confusing and inconsistent discussions of causality rather than culpability." The Court applied its change prospectively to litigants as to whom the six-year limitations had begun but had not yet expired. To this end, the Court found that Plaintiff's case was timely filed under the McKenzie rule. The Court reversed the appellate court's decision that dismissed Plaintiff's wantonness claim, and remanded the case for further proceedings.
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