Berlin v. Newman
In Berlin v. Newman, 657 So. 2d 890, 891 (Ala. Civ. App. 1994) a former wife sought to recover assets of her former husband that he allegedly had commingled with the assets of a later common-law wife. The plaintiff alleged that her former husband had diverted funds owed the plaintiff under the Alabama divorce judgment and had used them to purchase properties owned by the common-law wife, who was not an Alabama resident.
The court determined that the defendant common-law wife did not have sufficient contacts even though she had traveled to Alabama on more than one occasion, including coming here, before she was named as a party, to testify in the trial court on behalf of the former husband.
The court concluded that the mere possibility that the defendant and the former husband had colluded to hide the former husband's assets was not sufficient to establish the court's jurisdiction, even when coupled with the defendant's occasional visits to Alabama.