Brown v. Whitaker Contracting Corp
In Brown v. Whitaker Contracting Corp., 681 So. 2d 226 (Ala. Civ. App. 1996) the Court of Civil Appeals held that a trial judge making a Rule 54(b) certification of finality must, in addition to making a finding that "there is no just reason for delay," also state the reasons it finds "no just reason for delay."
Thereafter, the Court of Civil Appeals routinely remanded cases that did not meet the level of specificity required by Brown.