District Court Lacked Jurisdiction Over Workers’ Compensation Claim

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Zackery v. Huntley, [Ms. CL-2024-0127, Sep. 20, 2024] __ So. 3d __ (Ala. Civ. App. 2024). The court (Fridy, J.; Moore, P.J., and Edwards, Hanson, and Lewis, JJ., concur) dismisses Fredrick Zackery’s appeal from a judgment of the Etowah Circuit Court (“the circuit court”) awarding damages to Lucretia Huntley in her action for workers’ compensation benefits and reverses as unsupported by the evidence the judgment for Huntley for unpaid wages. Huntley filed this action in district court which entered a judgment in her favor which Zackery appealed to circuit court de novo.

Reiterating that “‘[w]orkmen’s compensation cases are required to be brought in circuit court regardless of amount sought,’” the court holds the district court lacked jurisdiction to adjudicate that claim. Ms. **6-7, quoting Baggett v. Webb, 46 Ala. App. 666, 672, 248 So. 2d 275, 280 (Civ. App. 1971). “Because a void judgment cannot support an appeal, Zackery’s appeal of the district court’s judgment did not properly bring before the circuit court Huntley’s workers’ compensation claim for de novo adjudication.” Ibid.

The court reverses the judgment against Zackery for unpaid wages because Huntley’s employer was Renaissance House, LLC, of which Zackery was a member. Zackery as “‘[a] member of a limited liability company is not liable, solely by reason of being a member, for a debt, obligation, or liability of the limited liability company or a series thereof, whether arising in contract, tort, or otherwise.’” Ms. *9, quoting § 10A-5A-3.01, Ala. Code 1975.

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