Henson v. Celtic Life Insurance Co
In Henson v. Celtic Life Insurance Co., 621 So. 2d 1268, 1272 (Ala. 1993), the Court held that it is not necessarily a requirement of a fraud claim that there be a direct communication between the one who makes the representation and the one to whom the representation is made.
If the fraudulent statement is made with the intent and expectation that the one to whom it is made will pass the statement on to the plaintiff, then the plaintiff is entitled to rely on that statement, even if it is not made personally or directly to the plaintiff. See id.