Alabama Court of Appeals April 16, 1918, 4 Div. 535. (Jinright v. Archer)

SAMFORD, J.

[1,2]

The first two counts of the complaint sufficiently state a cause of action for simple negligence, and were not subject to the demurrers interposed.

[3]

The third count of the complaint alleged that plaintiff’s injury was caused by the “recklessness, wantonness, and willfulness” of the defendant. This count was not subject to the demurrer interposed. Highland Ave. & Belt R. R. Co.