Alabama

Civil Procedure

Form 16 – Complaint for negligence or wantonness

1. On or about the ____ day of ____, upon a public highway [state the name of the street] in [City], County, Alabama, the defendant negligently [or wantonly] cause or allowed a motor vehicle to collide with a motor vehicle occupied by the plaintiff.

2. As a proximate consequence of the defendant’s said negligence [or wantonness], the plaintiff was caused to suffer the following injures and damages:

[enumerate injuries and damages].

Wherefore plaintiff demands judgment against defendant in the sum of _______ dollars and costs.

Committee Comments

Since contributory negligence is an affirmative defense, the complaint need contain no allegation of due care of plaintiff.