Robert L. Vaughn, Jr., aka Judson Vaughn v. William O. Bray, et al.

Can a trial court and The Supreme Court of Alabama ignore previous Supreme Court of Alabama decisions that protect plaintiffs in cases of undue influence? Spiva v. Boyd, 90 So. 289 (Ala.

declared: “In suits for relief on the ground of undue influence, neither limitations nor laches can begin to operate against the injured complainant so long as the undue influence itself continues.” However, in this action, Vaughn v. Bray, et al, the trial court ignored Spiva v. Boyd and ruled for the defendants based on the Doctrine of Latches — even though the evidence was clear that Teresa Bray, the sole beneficiary of the testator’s property, unduly influenced said testator until the testator’s death. Within a month of the testator’s death, the plaintiff filed a suit against the defendants. The Supreme Court of Alabama affirmed the trial court ruling.

Can a trial court and The Supreme Court of Alabama ignore a superseding authority and decide a case based not on the superseding authority, but rather on the law that the authority supersedes? Spiva v. Boyd is a superseding authority over statutes of limitations and the Doctrine of Latches in cases of undue influence. Spiva presents clear guidelines that protect plaintiffs — just as statutes of limitations protect defendants. Spiva v. Boyd is an Alabama state law that might be deemed (by some) as an unusual law, one perhaps that has few related or comparable laws in other states. But it is an important law that levels the playing field (in some circumstances) between plaintiffs and defendants in matters involving undue influence.