Union Planters v. The People of the State of NY

In this lien priority case, we certify three questions to the Alabama Supreme Court because there are no cases interpreting the Alabama statutes governing property bail bonds and when they become liens, and because we do not find clear guidance in the statutes themselves. “Where there is doubt in the interpretation of state law, a federal court may certify the question to the state supreme court to avoid making unnecessary Erie guesses and to offer the state court the opportunity to interpret or change existing law.” Tobin v. Mich. Mut. Ins. Co., 398 F.3d 1267, 1274 (11th Cir.2005).

I. FACTS…