Walden v. Es Capital, 1091474 (Ala. 5-20-2011), 89 So. 3d 90

Walden and Crooked Creek appeal Autauga Circuit Court's June 11, 2010 injunction restricting entry or control of the Danya Park Garden Apartments.
Montgomery Circuit Court had previously entered May 17, 2010 enforcement order aimed at Walden's challenge to its prior judgments; Autauga injunction addresses enforcement across courts.
Underlying litigation traces to Walden's 1991 loan to Smith, stock transfer, and a chain of judgments and orders affecting ownership of the Enterprises and the apartments.
Autauga summary-judgment in CV-04-390 (2006) held ES Capital's mortgage valid and superior; Walden's ownership claims were rejected, affirmed on appeal.
Crooked Creek, Walden, Ensley and others later pursued multiple actions in federal and state courts; Crooked Creek I/II and related actions concluded that ES's mortgage and the Hutchinson trust lien were valid.
In 2010, Ensley, ES, and Hutchinson sought to foreclose/retitle, while Walden transferred ownership claims to Crooked Creek and pursued related actions; venue and forum concerns arose.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Autauga's injunction was authority to counter Montgomery's enforcement order	Walden contends Autauga lacked jurisdiction to countermand Montgomery's order.	Ensley/ES/Hutchinson argue Autauga validly enjoined ongoing enforcement actions across courts.	Autauga had authority; injunction affirmed against Walden and Crooked Creek.
Whether the injunction complied with Rule 65(d)(2) requirements	Walden argues the order lacked explicit reasons and irreparable-harm nexus.	Effective rationale was provided; irreparable harm shown by continued vexatious litigation.	Order satisfied Rule 65(d)(2); upheld as sufficiently detailed.
Whether the Autauga action properly enjoined cross-venue litigation involving real property	Walden asserts improper cross-venue restraints and improper attempt to enforce prior judgments.	Court properly restrained vexatious suits and enforced law-of-the-case principles.	Court did not abuse its authority; injunction affirmed to prevent further vexatious suits.
Whether Ensley's mandamus petition to transfer the accounting action was proper venue	Crooked Creek/Senley contend Montgomery venue appropriate; Walden seeks Autauga/Elmore transfer.	Venue proper in Autauga or Elmore; Montgomery improper for an action against Ensley.	Mandamus granted; transfer to Autauga Circuit Court ordered.

Teleprompter of Mobile, Inc. v. Bayou Cable TV, 428 So. 2d 17 (Ala. 1983) (Rule 65(d)(2) requires explicit reasons and nexus for injunctions)
Butler v. Roome, 907 So. 2d 432 (Ala. 2005) (injunctions must specify reasons and irreparable harm)
Elliott v. Ole Town Ventures III, L.L.C., 777 So. 2d 132 (Ala. Civ. App. 2000) (reiterates Rule 65(d)(2) standards for injunctions)
Ex parte Pratt, 514 So. 2d 947 (Ala. 1987) (venue for real-estate actions determined by where land is situated)
Shomo Land Co. v. Johnson, 280 Ala. 398 (Ala. 1967) (venue for equity actions affecting land; choice between situs and residence)
Rush v. Simpson, 373 So. 2d 1105 (Ala. Civ. App. 1979) (concurrent jurisdiction; enforcement of decrees and ancillary proceedings)
Ex parte Overstreet, 748 So. 2d 194 (Ala. 1999) (mandatory transfer when venue is improper)
Ex parte Travis, 573 So. 2d 281 (Ala. 1990) (mandatory language of venue statutes and transfer rules)
Walden v. Hutchinson, 987 So. 2d 1109 (Ala. 2007) (mortgage validity and liens; law-of-the-case framework)
Ex parte L.N.K., So. 3d (Ala. Civ. App. 2010) (law-of-the-case and res judicata principles applied)