I-359, Inc. v. AmSouth Bank
In I-359, Inc. v. AmSouth Bank, 980 So. 2d 419, 422 (Ala. Ct. App. 2007), a claim alleging a breach of a covenant contained in a lease triggered the state's longer ten-year statute of limitations, whereas a claim alleging a breach of contract contained in the lease must be filed within the normal six-year statute of limitations period.
The alleged breaches all stemmed from the same lease agreement. Alabama's ten-year statute of limitations is similar to 7 CMC 2502(a)(2) and is applicable to: "actions for the recovery of lands, tenements or hereditaments or the possession thereof, except as otherwise provided in this article." Id. at 423 (citing Code of Ala. 6-2-33).