28 U.S.C. § 81
Section 81 · Alabama
Amended 3 times on record
Applied in 47 court decisions — leading case Freeman v. Bee Machine Co. (1943)
Most recently applied in AFC Franchising, LLC v. Danilo Purugganan (August 2022)
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
Alabama is divided into three judicial districts to be known as the Northern, Middle, and Southern Districts of Alabama.
(a) The Northern District comprises five divisions.
(1) The Northwestern Division comprises the counties of Colbert, Franklin, Lauderdale, and Lawrence.
Court for the Northwestern Division shall be held at Florence.
(2) The Northeastern Division comprises the counties of Cullman, Jackson, Limestone, Madison, Marshall, and Morgan.
Court for the Northeastern Division shall be held at Huntsville.
(3) The Southern Division comprises the counties of Blount, Jefferson, and Shelby.
Court for the Southern Division shall be held at Birmingham.
(4) The Eastern Division comprises the counties of Calhoun, Cherokee, Clay, Cleburne, DeKalb, Etowah, Saint Clair, and Talladega.
Court for the Eastern Division shall be held at Anniston.
(5) The Western Division comprises the counties of Bibb, Fayette, Greene, Lamar, Marion, Pickens, Sumter, Tuscaloosa, Walker, and Winston.
Court for the Western Division shall be held at Tuscaloosa.
(b) The Middle District comprises three divisions.
(1) The Northern Division comprises the counties of Autauga, Barbour, Bullock, Butler, Chilton, Coosa, Covington, Crenshaw, Elmore, Lowndes, Montgomery, and Pike.
Court for the Northern Division shall be held at Montgomery.
(2) The Southern Division comprises the counties of Coffee, Dale, Geneva, Henry, and Houston.
Court for the Southern Division shall be held at Dothan.
(3) The Eastern Division comprises the counties of Chambers, Lee, Macon, Randolph, Russell, and Tallapoosa.
Court for the Eastern Division shall be held at Opelika.
(c) The Southern District comprises two divisions.
(1) The Northern Division comprises the counties of Dallas, Hale, Marengo, Perry, and Wilcox.
Court for the Northern Division shall be held at Selma.
(2) The Southern Division comprises the counties of Baldwin, Choctaw, Clarke, Conecuh, Escambia, Mobile, Monroe, and Washington.
Court for the Southern Division shall be held at Mobile.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Historical and Revision Notes
Based on title 28, U.S.C., 1940 ed. §142 (Mar. 3, 1911, ch. 231, §70, 36 Stat. 1105; Feb. 28, 1913, ch. 89, 37 Stat. 698; June 27, 1922, ch. 247, 42 Stat. 667).
Provisions relating to the places for the maintenance of the clerks' offices were omitted as covered by section 751 of this title, providing that deputy clerks may be designated to reside and maintain offices at such places for holding court as the judge may determine.
Provisions that the offices of the court shall be kept open at all times were omitted as covered by section 452 of this title.
A provision requiring the district judge for the northern district to reside at Birmingham was omitted as incongruous with section 134 of this title, requiring every district judge to reside within the district for which he is appointed. Likewise the provision of section 142 of title 28, U.S.C., 1940 ed., requiring the court to remain in session at Birmingham at least 6 months in each calendar year was omitted as unnecessary and not in harmony with provisions respecting other districts.
The provisions for furnishing rooms and accommodations at Florence, Gadsden, Jasper and Opelika were omitted as obsolete upon advice of the Director of the Administrative Office of the United States Courts that Federal accommodations are now available in each of these places.
Changes in arrangement and phraseology were made.
Editorial Notes
Amendments
2024—Subsec. (a). Pub. L. 118–179, §1(1), substituted "five" for "seven" in introductory provisions.
Subsec. (a)(1). Pub. L. 118–179, §1(2), substituted "Lauderdale, and Lawrence" for "and Lauderdale".
Subsec. (a)(2). Pub. L. 118–179, §1(3), struck out Lawrence and added Marshall to the counties comprising the Northeastern Division of the Northern District and struck out "and Decatur" after "Huntsville".
Subsec. (a)(4). Pub. L. 118–179, §1(4), substituted "Cherokee, Clay, Cleburne, DeKalb, Etowah, Saint Clair," for "Clay, Cleburne,".
Subsec. (a)(5). Pub. L. 118–179, §1(5), substituted "Fayette, Greene, Lamar, Marion, Pickens, Sumter, Tuscaloosa, Walker, and Winston" for "Greene, Pickens, Sumter, and Tuscaloosa".
Subsec. (a)(6). Pub. L. 118–179, §1(6), struck out par. (6) which read as follows: "The Middle Division comprises the counties of Cherokee, De Kalb, Etowah, Marshall, and Saint Clair.
"Court for the Middle Division shall be held at Gadsden."
Subsec. (a)(7). Pub. L. 118–179, §1(7), struck out par. (7) which read as follows: "The Jasper Division comprises the counties of Fayette, Lamar, Marion, Walker, and Winston.
"Court for the Jasper Division shall be held at Jasper."
1961—Subsec. (a)(2). Pub. L. 87–36 provided for holding court at Decatur.