Woodruff v. City of Tuscaloosa, 101 So. 3d 749

Woodruff was arrested October 16, 2006 at the Tuscaloosa Police Department on a warrant for harassing communications, and was booked after an officer handcuffed him.
While waiting in the lobby, Woodruff had a verbal altercation with off-duty officer Summers and was charged with disorderly conduct.
Woodruff was convicted of disorderly conduct on November 15, 2006, and sought a trial de novo; the charge was nol-prossed on January 2, 2009.
On January 3, 2011, Woodruff filed suit alleging malicious prosecution, false imprisonment, and the tort of outrage against the City, its officers, and others involved.
The City and individual defendants moved to dismiss; Woodruff sought a default judgment when service errors allegedly occurred; the trial court dismissed the claims on May 31, 2011, and Woodruff appealed.
The court affirms, holding that the City’s service error did not deprive the court of authority to rule on the motions and that the challenged claims fail as a matter of law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court lacked jurisdiction due to improper service	Woodruff argues the City’s failure to serve dismissed motions deprived the court of jurisdiction	City contends service was remedied and the court could proceed	Trial court had jurisdiction; service error remedied, motions properly considered
Whether Woodruff can establish malicious prosecution	Woodruff claims the City instigated prosecution without probable cause and with malice	Conviction and probable cause bar malicious-prosecution claim	Dismissal proper; no viable malicious-prosecution claim
Whether Woodruff can prove false imprisonment	Disorderly-conduct charge was baseless and caused detention	He was already under a valid harassing-communications warrant	Dismissal proper; no false-imprisonment claim
Whether Woodruff can prove outrage claim	Claims of community-wide outrage due to City’s pattern of misconduct	Outrage not recognized here and requires extreme distress	Outrage claim properly dismissed; no extreme emotional distress shown

Crosslin v. Health Care Authority of Huntsville, 5 So.3d 1193 (Ala.2008) (standard for Rule 12(b)(6) dismissal in Alabama)
Nichols v. Pate, 992 So.2d 734 (Ala.Civ.App.2008) (service deficiencies and jurisdiction concerns on motion practice)
Ex parte Kemp, 202 Ala. 425, 80 So. 809 (Ala.1919) (probable-cause evidence after conviction remains relevant)
Callens v. Jefferson County Nursing Home, 769 So.2d 273 (Ala.2000) (elements of the tort of outrage (IIED))
Ennis v. Beason, 537 So.2d 17 (Ala.1988) (false-arrest/imprisonment limitations under valid warrant)
Gunter v. Pemco Aeroplex, Inc., 646 So.2d 1332 (Ala.1994) (probable cause evidenced by prior conviction)
Fina Oil & Chem. Co. v. Hood, 621 So.2d 253 (Ala.1993) (malicious-prosecution elements and required showing)
Crutcher v. Wendy’s of North Alabama, Inc., 857 So.2d 82 (Ala.2003) (false-imprisonment framework under statutory guidance)