Crusoe v. Davis

I write specially to address a potential alternative ground for affirming the trial court’s order — the applicability to this case of § 32-10-11, Ala.Code 1975, the accident-report-confidentiality statute. Although neither party cited this statute in its briefs, “[t]his Court may affirm the judgment of the trial court upon any valid legal ground even if that ground was not argued before or considered by ... the trial court,” Ex parte Jones, 147 So.3d 415, 419 (Ala.2013), so long as certain due-process constraints are observed. Liberty Nat’l Life Ins. Co. v. University of Alabama Health Servs.…