Ala. R. Civ. P. Form 16
As amended through September 26, 2024
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.
Ala. R. Civ. P. Form 16
Committee Comments
Since contributory negligence is an affirmative defense, the complaint need contain no allegation of due care of plaintiff.