Sho-Me Motor Lodges, Inc. v. Jehle-Slauson Construction Co

In Sho-Me Motor Lodges, Inc. v. Jehle-Slauson Construction Co., 466 So. 2d 83 (Ala. 1985), the Court held that the following language, which concluded two summary-judgment orders, made the two orders final pursuant to Rule 54(b) even though the language did not mention Rule 54(b) and even though it stated no "express direction" for the entry of final judgments: "The Court further finds there is no just reason for delay in the entry of said final judgment." 466 So. 2d at 87. The Court held in Sho-Me that if it is clear and obvious from the language used by the trial court in its order that the court intended to enter a final order pursuant to Rule 54(b), then we will treat the order as a final judgment: "Of course, Rule 54(b) requires 'an express determination that there is no just reason for delay.' Each of these judgments contains the express language that 'the Court further finds that there is no just reason for delay.' Moreover, Rule 54(b) requires 'an express direction for the entry of judgment.' Each of these judgments contains the express language 'motion for summary judgment granted,' and both continue, 'there is no just reason for delay in the entry of said final judgment.'