Frederick Van Diver v. Anietra Mays

CourtSupreme Court of Alabama
DecidedApril 10, 2026
DocketSC-2025-0660
StatusPublished

This text of Frederick Van Diver v. Anietra Mays (Frederick Van Diver v. Anietra Mays) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Frederick Van Diver v. Anietra Mays, (Ala. 2026).

Opinion

Rel: April 10, 2026

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is printed in Southern Reporter.

SUPREME COURT OF ALABAMA OCTOBER TERM, 2025-2026

_________________________

SC-2025-0660 _________________________

Frederick Van Diver

v.

Anietra Mays

Appeal from Montgomery Circuit Court (CV-23-900805)

McCOOL, Justice.

Frederick Van Diver has appealed from a default judgment entered

against him by the Montgomery Circuit Court. For the reasons set forth SC-2025-0660

herein, we affirm the judgment insofar as it imposes liability on Van

Diver, but we reverse the award of damages and remand the case to the

circuit court for that court to reconsider the damages.

Facts and Procedural History

In June 2023, Anietra Mays filed a complaint against Van Diver;

American Benefit, LLC ("American Benefit"); and Mutual of Omaha

Insurance Company ("Omaha"). According to the complaint, at all times

relevant to this case, Van Diver was an employee of American Benefit,

which "was a subsidiary of Omaha." In support of her complaint, Mays

alleged that, during the time that she and her husband were in the

process of divorcing, Van Diver had assisted her husband in "obtain[ing]

life insurance on [her] life without [her] knowledge." Specifically, Mays

alleged that Van Diver had "forged [her] signature on the application for

life insurance" and that her husband had then purchased the life-

insurance policy from Omaha and had named himself the beneficiary of

the policy. Relying on those allegations, Mays asserted a claim of fraud

against Van Diver and asserted a claim of negligent or wanton hiring,

training, and supervision against American Benefit and Omaha. Mays

did not seek a specific amount of damages in her complaint but, instead,

2 SC-2025-0660

sought a judgment "in an amount that exceeds the minimal jurisdictional

limits of [the circuit court] … whether the same be compensatory or

punitive."

In July 2023, Omaha filed a motion to dismiss Mays's claim against

it, arguing that it "did not issue any [life-insurance] policy to [Mays] or

her ex-husband." In fact, Omaha argued, the application for a life-

insurance policy had not even been "submitted to Omaha; it [had been]

submitted to United of Omaha Life Insurance Company, which is a

different legal entity," and, according to Omaha, "United of Omaha [had]

declined to issue the policy." (Emphasis omitted.) Omaha included with

its motion a letter that United had sent to Mays, informing her that her

application for a life-insurance policy had been denied.

There is no indication in the record that, following the filing of

Omaha's motion to dismiss, any activity occurred in this case until June

2024, when the circuit court scheduled a hearing on that motion to be

held the following month. It is unclear from the record whether that

hearing occurred, but, in September 2024, Mays stipulated to Omaha's

dismissal from the case, and the circuit court entered an order to that

effect. The circuit court also scheduled a status conference to be held in

3 SC-2025-0660

October 2024. Again, it is unclear from the record whether that hearing

occurred, but Mays contends that it did and that, at that hearing, the

circuit court "recommended [that Mays] withhold from filing a [motion

for a] default judgment as such may be easily overturned." Thus, it does

not appear that Van Diver was present at that hearing, and he does not

contend that he was.

On April 4, 2025, the circuit court notified Mays that Van Diver and

American Benefit had not yet been served with the complaint and warned

her that, if she failed to perfect service within 14 days, her complaint

could be dismissed. Mays apparently took no action in response to that

notice, and, on April 22, 2025, the circuit court dismissed her complaint,

without prejudice, for failure to perfect service. The next day, Mays filed

a motion to reconsider and, in support of her motion, attached the return

of service showing that Van Diver had been served with the complaint

and a summons on October 6, 2023. It is undisputed that Van Diver was

in fact served with the complaint and a summons by certified mail on

that day.

On May 20, 2025, the circuit court held a hearing on Mays's motion

to reconsider. At that time, Van Diver was not yet represented by

4 SC-2025-0660

counsel, and neither he nor American Benefit appeared for that hearing.

Later that day, the circuit court issued an order providing that Mays had

30 days within which to file a motion for a default judgment against Van

Diver and had 60 days within which to serve American Benefit with the

complaint in order to avoid the dismissal of American Benefit from the

case.1

On June 16, 2025, Mays filed a motion for a default judgment

against Van Diver, arguing that he had "failed to answer or otherwise

defend as to [the] complaint" despite being served with the complaint in

October 2023. Mays sought $200,000 in damages but did not explain how

she had arrived at that amount. The next day, the circuit court entered

a default judgment against Van Diver and awarded Mays $200,000 in

damages.

On August 8, 2025, Paul M. James, Jr., entered his notice of

appearance as counsel for Van Diver. That same day, pursuant to Rule

1It appears that the circuit court considered its May 20, 2025, order

as an entry of default against Van Diver. See Rule 55(a), Ala. R. Civ. P.; and Justice v. Wallace, 272 So. 3d 651, 653 (Ala. Civ. App. 2018) (" '[A] party must first obtain an entry of default by the clerk or the trial court before he or she can obtain a default judgment from the trial court.' " (citation omitted)). 5 SC-2025-0660

60(b)(1), Ala. R. Civ. P., Van Diver filed a motion to set aside the default

judgment on the basis of "mistake, inadvertence, surprise, or excusable

neglect." In support of his motion, Van Diver submitted his affidavit,

which states, in pertinent part:

"I am not an attorney, nor do I have legal experience. I have never defended myself pro se in any matter, either criminal or civil.

"On October 6, 2023, I executed a Return on Service of the Complaint and Summons in this case, via Certified Mail.

"However, at the time, I had no knowledge or understanding of the implications and consequences of this action, nor did I understand or have any knowledge of the procedural rules regarding the timeline for responding to and filing certain pleadings and filings in the present matter, or in civil court, generally.

"I was unsure at that time what the term 'appear' or 'appearance' meant in the context of a civil action."

Van Diver further stated that he had had discussions with John S.

Johnson, who had served as counsel for Omaha, and that those

discussions had led him to believe that there was nothing he needed to

do to protect himself. Specifically, Van Diver stated:

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