Court Overrules
Ex parte Scott Bridge Company
Ex parte Mercedes-Benz U.S. International, Inc.
In
Ex parte Mercedes-Benz U.S. International, Inc.
, an employee for Mercedes-Benz U.S. International, Inc. (“MBUSI”) filed a workers’ compensation claim against the company in Jefferson County, Alabama. MBUSI, which is headquartered and maintains its principal place of business in Tuscaloosa County, filed a motion to transfer the case to Tuscaloosa County, asserting that venue in Jefferson County was improper under Ala. Code § 6-3-7(a)(2) and (3). The trial court denied MBUSI’s motion to transfer; and on a petition for a writ of mandamus, the Alabama Court of Civil Appeals, relying on
Ex parte Scott Bridge Co.
,
834 So. 2d 79 (2002),
denied MBUSI’s motion to transfer as well. The Court of Civil Appeals reasoned that venue was proper in Jefferson County because MBUSI did “business by agent” in Jefferson County by purchasing automobile parts from its suppliers located there.
The Alabama Supreme Court, however, noted that its Justices have since questioned the underlying premise of
Scott Bridge
’s holding that the purchase of materials in a county constitutes “doing business by agent” in that county for purposes of determining proper venue. Contrary to the holding in
Scott Bridge
, the Court emphasized the well-established principle that “[a] corporation ‘does business’ in a county for [venue] purposes if, with some regularity, it performs there some business functions for which it was created.” Regarding MBUSI’s purchase of automobile parts from its suppliers in Jefferson County, the Court noted that this business function was “merely a necessary incident” to its business of manufacturing automobiles rather than the exercise of a business function for which it was created. Thus, the Alabama Supreme Court overruled
Scott Bridge
due to its
inconsistency with this well-established principle,
and directed the trial court to vacate its order denying MBUSI’s motion to transfer.
