The Alabama Supreme Court dismissed separate appeals filed by a trial judge and a defendant in an unusual case involving overlapping domestic violence proceedings and judicial authority.
Judge Linda F. Coats and Jordan Ray Henshaw both challenged the same Madison Circuit Court order that issued writs of mandamus affecting their respective positions in a protection-from-abuse case. The Supreme Court dismissed Judge Coats's appeal entirely and dismissed part of Henshaw's appeal while transferring the remainder to the Court of Criminal Appeals.
The case originated when Mikaela Williams, Henshaw's girlfriend, filed a petition for protection from abuse against Henshaw on March 10, 2025, in Madison Circuit Court under Alabama's Protection from Abuse Act. The petition stemmed from an incident that also resulted in separate criminal charges against Henshaw.
The Madison Circuit Court subsequently issued a writ of mandamus directing Judge Coats to vacate portions of an order she had entered in the protection-from-abuse case. The circuit court also issued a separate mandamus order requiring Judge Patricia D. Demos to vacate her order dismissing a domestic-abuse charge against Henshaw that arose from the same underlying incident.
Both Judge Coats and Henshaw filed separate appeals to the Alabama Supreme Court challenging these mandamus orders. Such dual appeals from different parties regarding the same court order represent an unusual procedural situation in Alabama's appellate system.
Judge Coats appealed the mandamus order directing her to modify her ruling in the protection case, likely raising questions about judicial independence and the appropriateness of using mandamus to compel specific judicial actions. Trial judges typically have broad discretion in managing cases before them, and mandamus relief against judicial officers is generally reserved for clear abuses of authority or failures to perform ministerial duties.
Henshaw's appeal challenged both mandamus orders - the one affecting Judge Coats's protection order and the one requiring Judge Demos to reinstate the criminal charges against him. His appeal likely argued that the circuit court exceeded its authority in issuing the writs or that the underlying orders were proper as originally entered.
The Alabama Supreme Court's decision to dismiss Judge Coats's appeal suggests the court found her challenge lacked merit or that she lacked standing to contest the mandamus order. Courts are generally reluctant to allow judges to appeal orders directing them to take specific actions in pending cases, as this could create conflicts with the orderly administration of justice.
Regarding Henshaw's appeal, the Supreme Court dismissed part of it while transferring the remainder to the Court of Criminal Appeals. This split treatment indicates that some issues in Henshaw's appeal fell within the Supreme Court's civil jurisdiction while others belonged in the specialized criminal appeals court.
The transfer to the Court of Criminal Appeals likely involves the portion of Henshaw's appeal challenging the mandamus order that required Judge Demos to reinstate the criminal domestic violence charges. Alabama's Court of Criminal Appeals has exclusive jurisdiction over most criminal matters, including appeals challenging the dismissal or reinstatement of criminal charges.
The case highlights the complex interplay between civil protection orders and criminal prosecutions in domestic violence cases. When the same incident generates both a civil protection petition and criminal charges, courts must carefully coordinate proceedings to avoid conflicting orders or double jeopardy issues.
Protection from abuse cases in Alabama allow alleged victims to seek immediate court orders prohibiting contact, requiring the alleged abuser to stay away from certain locations, and addressing temporary custody or support issues. These civil proceedings operate independently of any criminal prosecution, though courts often consider both when fashioning appropriate relief.
The use of mandamus relief in this case also raises questions about appellate oversight of trial court decisions. Mandamus is an extraordinary remedy typically reserved for situations where a lower court has clearly exceeded its jurisdiction or failed to perform a ministerial duty. The fact that the Madison Circuit Court found mandamus appropriate here suggests significant concerns about the original orders entered by both Judge Coats and Judge Demos.
The Alabama Supreme Court's dismissal of these appeals effectively upholds the circuit court's mandamus orders, requiring both judges to comply with the directed modifications to their rulings. This outcome reinforces the principle that higher courts can compel trial judges to correct legal errors through mandamus when appropriate, even when the judges themselves contest such directives.
The case serves as a reminder of the procedural complexities that can arise in domestic violence cases involving multiple legal proceedings and the importance of coordinated judicial responses to ensure consistent application of the law while protecting all parties' rights.