Alfa Mutual Insurance Co. v. Culverhouse, 149 So. 3d 1072

Culverhouse obtained an Alfa homeowners policy during/after construction of his Hartford house, with Koch as the agent.
Fire destroyed the house again in July 2009; Alfa investigated but could not determine the cause.
Culverhouse claimed $934,450 total loss; Alfa questioned the claim for insufficient inventories, insufficient proof of loss, and lack of support for loss-of-use, contents, and other structures.
Culverhouse sat for an oath examination; he admitted some submitted information was inaccurate and later provided more itemized lists, which Alfa found insufficiently specific.
Alfa offered a settlement of $464,600 (rebuild) plus $100,000 for other claims; Culverhouse demanded policy limits of $975,700 and sued for breach, negligence, fraud, and bad faith.
Summary judgment was granted in favor of Alfa; Culverhouse moved to alter/amend/vacate (Rule 59(e)); the trial court amended to exclude breach-of-contract claim, later allowing appeal on the post-judgment argument.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused discretion in considering a new post-judgment argument	Culverhouse argues trial court acted within discretion to hear belated argument.	Alfa asserts lack of justification for raising new argument; discretionary but not mandatory to consider.	Trial court acted within discretion to consider belated argument.
Whether the post-judgment argument justified altering the summary judgment	Culverhouse contends the new argument shows genuine issues warranting reconsideration.	Alfa contends new arguments without justification are improper to alter judgment.	Court upheld the amended judgment; no abuse of discretion.

Moore v. Glover, 501 So.2d 1187 (Ala. 1986) (new post-judgment evidence requires justification to be considered)
Green Tree Acceptance, Inc. v. Blalock, 525 So.2d 1366 (Ala.1988) (trial court may consider new legal arguments in post-judgment motion but not required)
Maxwell v. Dawkins, 974 So.2d 282 (Ala.2006) (discretion to consider belated arguments; justification not mandatory)