In Wal-Mart Stores v. Kennedy, 799 So. 2d 188 (Ala. Civ. App. 2001), the Court of Civil Appeals of Alabama held that “[t]he inability to perform one's trade and to find gainful employment.” is the test for permanent total disability. In Michelin N. Am., Inc. v. Hamby, 722 So. 2d 770 (Ala. Civ. App. 1998) it was held that:

“The court must apply a two-pronged test in determining whether a permanent total disability exists: the employee must be found to be incapable of returning to his trade, as well as incapable of being retrained for gainful employment. Id. Total disability does not mean an entire physical disability or absolute helplessness.” Id, at 773.

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