In a case that clarifies the bounds of jurisdiction for mandamus petitions, the Alabama Court of Appeals recently heard an appeal arising from Mobile County. This case, Ex Parte State of Alabama, explores trial court jurisdiction time limits without a stay, defining when new judgments can be issued, and orders enforced.
In December of 2019, Tramaine Bonner was convicted of two counts of first-degree robbery in a jury trial. Before sentencing, Bonner filed a motion for judgement of acquittal, arguing that the evidence against him could only sustain a third-degree robbery conviction, and was insufficient for a first-degree charge. Judge Michael Youngpeter granted Bonner’s motion on March 1, 2023, acquitting Bonner of first-degree robbery and finding Bonner guilty of third-degree robbery. Despite the reduced charge, Bonner received a life sentence due to his previous felony convictions.
Following Judge Youngpeter’s ruling, the State petitioned for a writ of mandamus. 29 days after Judge Youngpeter’s acquittal, on March 30, 2023, the Court ordered Judge Youngpeter to reinstate Bonner’s original first-degree robbery conviction, setting aside his acquittal. Bonner petitioned the Alabama Supreme Court to review the Court’s order, but the Supreme Court declined. On September 5, 2023, Judge Youngpeter declined to set aside the acquittal, concluding that the trial court’s jurisdiction expired after 30 days without a stay. As a result, appellate courts lacked jurisdiction to order Judge Youngpeter to vacate his earlier judgment.
On review, the Court of Criminal Appeals clarified the proper application of the thirty-day time limit. The Court issued its March 30 order before its jurisdiction expired on March 31. Additionally, the Court had the authority to enforce the order beyond the period of jurisdiction, with compliance serving as a ministerial act. Despite the State’s successful petition to reinstate Bonner’s original convictions, the Court emphasized the importance of requesting a stay when pursuing mandamus relief to avoid possible jurisdictional issues.
Ex Parte State of Alabama serves as an example of the proper application of time limits for court jurisdiction. Although following through with the order exceeded the period of jurisdiction, the order itself was timely, and the nature of the order made compliance lawful. Thus, despite delays, the writ of mandamus was properly issued.
If you have a Federal Criminal case, a State Criminal case, a Municipal Case or a Family Law case, contact Joe Ingram or Joe Ingram Law LLC at 205-335-2640 or 205-506-5590.
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