Gunter v. Huddle
In Gunter v. Huddle, 724 So. 2d 544 (Ala. Civ. App. 1998) the Court of Civil Appeals held that a sexual relationship between a patient and a nonpsychiatric physician was outside the scope of the physician's professional services and did not constitute professional malpractice, in the absence of evidence that the patient had been led to believe by that physician that the sexual relationship was part of the patient's treatment. 724 So. 2d at 546.
Although the Gunter decision presented a question of first impression in Alabama, the decision followed the general rule applied in other jurisdictions.