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Feb. 20, 2026 Get Citation Alerts Download PDF Add Note

Jordan Ray Henshaw v. State of Alabama

Supreme Court of Alabama

• Citations: None known
• Docket Number: SC-2025-0535

• Judges: Mendheim, J.

• Opinion

• Authorities (27)

• Cited By (0)

• Summaries (0)

• Similar Cases (14K)

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Combined Opinion

Rel: February 20, 2026

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern
Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts,
300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other
errors, in order that corrections may be made before the opinion is printed in Southern Reporter.

SUPREME COURT OF ALABAMA
OCTOBER TERM, 2025-2026

---

SC-2025-0493

---

Judge Linda F. Coats

v.

State of Alabama

Appeal from Madison Circuit Court
(CV-25-94)

---

SC-2025-0535

---

SC-2025-0493; SC-2025-0535

Jordan Ray Henshaw

v.

State of Alabama

Appeal from Madison Circuit Court
(CV-25-94)

MENDHEIM, Justice.

Judge Linda F. Coats and Jordan Ray Henshaw separately appeal

from a Madison Circuit Court order insofar as it issued a writ of

mandamus to Judge Coats requiring her to vacate a portion of an order

she had entered in a protection-from-abuse case that had been filed by

Henshaw's girlfriend, Mikaela Williams. Judge Coats and Henshaw also

separately appeal from that same Madison Circuit Court order insofar as

it issued a writ of mandamus requiring Judge Patricia D. Demos to

vacate her order dismissing a domestic-abuse charge against Henshaw

that stemmed from the same incident that led to the protection-from-

abuse case. We dismiss Judge Coats's appeal, and we dismiss in part

Henshaw's appeal, and transfer it to the Court of Criminal Appeals.

2
SC-2025-0493; SC-2025-0535

I. Facts

On March 10, 2025, Williams filed a petition for protection from

abuse ("PFA") against Henshaw in the Madison Circuit Court, pursuant

to the Protection from Abuse Act ("the PFAA"), Ala. Code 1975, § 30-5-1

et seq. The petition alleged that Henshaw and Williams were in a dating

relationship and that, on March 9, 2025, Henshaw had hit, choked, and

punched Williams. The PFA petition was assigned case number DR-

2025-3118 ("the PFA case"). Judge Coats, a district-court judge in

Madison County, was assigned the PFA case because, on January 2,

2025, she had been appointed as a special circuit-court judge by Madison

County's then-Presiding Circuit Judge Alison Austin.1 In her capacity as

a special circuit-court judge, Judge Coats, on March 10, 2025, granted an

1Presumably Judge Coats's appointment was made pursuant to
Rule 13(A), Ala. R. Jud. Adm., which provides:

"(A) A presiding circuit court judge, by order, may assign
a judge who is within the circuit to serve within the circuit
courts or within the district courts of the circuit. Before
assigning a judge, the presiding circuit court judge shall
evaluate the needs of the circuit, including the currency,
congestion, and backlog of criminal and civil cases. This
assignment shall continue until revoked by the presiding
judge or until the assigned judge leaves office, whichever
comes first."
3
SC-2025-0493; SC-2025-0535

ex parte protection order against Henshaw that restrained him from

having any contact with Williams until a further order was entered by

Judge Coats, and she set a hearing for the PFA petition to be held on

March 24, 2025. On that same date, Judge Coats also entered in the PFA

case an "Order for Separate Accommodations" that would allow Williams

to have "separate accommodations from [Henshaw] while waiting at the

courthouse for scheduled court appearances." That order expressly listed

Judge Coats as sitting as "Special Circuit Judge." Because Henshaw

initially was unable to be located for service of the PFA petition, Judge

Coats entered an order on March 26, 2025, resetting the hearing on the

PFA petition for May 5, 2025. That order also expressly listed Judge

Coats as sitting as "Special Circuit Judge."

On March 11, 2025, an arrest warrant was issued for Henshaw,

charging him with domestic violence in the third degree based on the

same conduct that formed the basis of the PFA petition. On April 23,

2025, Henshaw was arrested for the criminal charge, and he was served

the PFA petition. The criminal case was brought by the Madison County

District Attorney against Henshaw in the Madison District Court before

4
SC-2025-0493; SC-2025-0535

Judge Patricia D. Demos, and it was assigned case number DC-2025-

2191 ("the criminal case").

On May 2, 2025, Henshaw's counsel filed in the PFA case a "Motion

for Pre-Trial Immunity Hearing and Motion to Dismiss."2 In that motion,

Henshaw asserted that "he is immune from prosecution based on a theory

of self-defense pursuant to § 13A-3-23(a), (b) & (d), Code of Alabama,

1975." Henshaw argued that he was "entitled to a pretrial immunity

hearing" based on his "claim of self-defense pursuant to § 13A-3-23(a), (b)

& (d), Code of Alabama, 1975," and asked Judge Coats to "find [Henshaw]

immune from prosecution and/or civil action, and, accordingly, dismiss

this cause, discharging [Henshaw] from any further obligation to the

court in relation to the matters giving rise to the action here within." In

other words, Henshaw argued that he was entitled to a hearing for

statutory stand-your-ground immunity under § 13A-3-23(d), Ala. Code

1975.3 The Madison County District Attorney did not receive notice of

Henshaw's immunity motion filed in the PFA case.

2Although Henshaw's counsel filed the motion in the PFA case, the

header for the motion stated: "In the District Court of Madison, County,
Alabama."

3Section 13A-3-23(d), Ala. Code 1975, provides:

5
SC-2025-0493; SC-2025-0535

On May 5, 2025, Judge Coats held a pretrial hearing on the issue

whether Henshaw was entitled to statutory stand-your-ground immunity

in the PFA case. On May 7, 2025, Henshaw's counsel submitted in the

"(d)(1) A person who uses force, including deadly
physical force, as justified and permitted in this section is
immune from criminal prosecution and civil action for the use
of such force, unless the force was determined to be unlawful.

"(2) Prior to the commencement of a trial in a case in
which a defense is claimed under this section, the court
having jurisdiction over the case, upon motion of the
defendant, shall conduct a pretrial hearing to determine
whether force, including deadly force, used by the defendant
was justified or whether it was unlawful under this section.
During any pretrial hearing to determine immunity, the
defendant must show by a preponderance of the evidence that
he or she is immune from criminal prosecution.

"(3) If, after a pretrial hearing under subdivision (2), the
court concludes that the defendant has proven by a
preponderance of the evidence that force, including deadly
force, was justified, the court shall enter an order finding the
defendant immune from criminal prosecution and dismissing
the criminal charges.

"(4) If the defendant does not meet his or her burden of
proving immunity at the pre-trial hearing, he or she may
continue to pursue the defense of self-defense or defense of
another person at trial. Once the issue of self-defense or
defense of another person has been raised by the defendant,
the state continues to bear the burden of proving beyond a
reasonable doubt all of the elements of the charged conduct."

6
SC-2025-0493; SC-2025-0535

PFA case a draft order granting Henshaw immunity.4 On May 8, 2025,

Judge Coats entered an "Order on Immunity Hearing and Order Denying

Petition for Protection from Abuse."5 In that order, Judge Coats stated

that she

"conducted the pre-trial immunity hearing in accordance with
Alabama law to determine whether [Henshaw] acted within
the parameters of Alabama law regarding the issue of self-
defense, and whether the law entitled [Henshaw] to immunity
from criminal prosecution and civil action arising from the
conduct alleged, as provided in Ala. Code § 13A-3-23(d)(1).
Present for the hearing was the Plaintiff/Petitioner, M[i]kaela
Williams, pro se, [and] Defendant/Respondent, Jordan
Henshaw, who was represented by his Attorney of Record,
Larry Marsili.

"At the hearing, the Court took evidence, including the
sworn testimony of both [Williams] and [Henshaw], as well as
testimony from other witnesses called to testify by [Williams].
Details of allegations of abuse and assault resulting from an
altercation involving the parties on or about March 9, 2025,
were the subject of the litigation.

"Having considered the evidence and testimony, this
Court finds that [Henshaw] acted lawfully in self-defense in

4Like Henshaw's motion, the draft order's header stated: "In the

District Court of Madison County, Alabama," and below the blank
signature line for Judge Coats it stated: "District Judge."

5The May 8, 2025, order was identical to the draft order submitted

by Henshaw's counsel in every way except that it contained a
handwritten "8" in the blank for the day it was entered and contained
Judge Coats's signature above her printed name. Thus, the designation
"District Judge" remained below Judge Coats's printed name.
7
SC-2025-0493; SC-2025-0535

accordance with the provisions of Ala. Code § 13A-3-23. The
giggling, smirking and general demeanor of [Williams] during
her testimony was particularly troubling to the Court with
respect to her credibility. The Court further finds that
specifically Ala. Code § 13A-3-23(c)(1), (c)(2), and (c)(3) are not
applicable so as to bar [Henshaw] from prevailing on a claim
of self-defense under this Code section.[6] As such, [Henshaw]
is entitled to the relief requested of immunity from criminal
prosecution and civil action resulting from the altercation
between the parties, which was the subject of the proceedings.

"It is therefore ORDERED, ADJUDGED, and
DECREED that [Williams's] Petition for Protection from
Abuse is DENIED, and the Court's previous Ex parte Order

6Section 13A-3-23(c), Ala. Code 1975, provides:

"(c) Notwithstanding the provisions of subsection (a), a
person is not justified in using physical force if:

"(1) With intent to cause physical injury or
death to another person, he or she provoked the
use of unlawful physical force by such other
person.

"(2) He or she was the initial aggressor,
except that his or her use of physical force upon
another person under the circumstances is
justifiable if he or she withdraws from the
encounter and effectively communicates to the
other person his or her intent to do so, but the
latter person nevertheless continues or threatens
the use of unlawful physical force.

"(3) The physical force involved was the
product of a combat by agreement not specifically
authorized by law."
8
SC-2025-0493; SC-2025-0535

for Protection from Abuse entered on March 10, 2025, is
WITHDRAWN and VACATED."

(Capitalization and bold typeface in original; other emphasis added.)

On the same day, May 8, 2025, Henshaw filed a "Motion to Dismiss"

in the criminal case. In his motion, Henshaw related that there had been

a pending PFA case "concerning the same allegations which give rise to

the instant case." Henshaw's motion then stated:

"4. After a hearing on the merits, a determination was
made by the Court that [Henshaw] acted lawfully in self-
defense and an Order reflecting the same was entered on May
8, 2025 (copy attached hereto as 'Exhibit 2').

"5. [Henshaw] has been deemed immune from criminal
prosecution and civil action for this matter by way of the
aforementioned Court Order.

"6. Ala. Code § 13A-3-23, as referenced in said Order
grants [Henshaw] immunity from criminal prosecution and
civil action relating to the conduct alleged.

WHEREFORE, the PREMISES CONSIDERED,
[Henshaw] requests that this Honorable Court enter an Order
dismissing the pending charge with prejudice."

(Capitalization in original; emphasis added.)

On May 14, 2025, Judge Demos entered an "Order of Dismissal" in

the criminal case that provided:

"[Henshaw] has filed a motion to dismiss based on the
findings of Judge Coats after a hearing in DR-2025-3118. The
9
SC-2025-0493; SC-2025-0535

Court in that case conducted a hearing under Alabama Code
§ 13A-3-23 and after taking testimony determined that
[Henshaw] was entitled to immunity from criminal and civil
prosecution in that cause.

"Furthermore, it is undisputed that the facts giving rise
to the Petition for Protection from Abuse filed in DR-2025-
3118 are the same facts as alleged in the complaint in this
cause; are the same facts to which were testified at hearing;
and the same facts on which immunity was granted.
Therefore, based on the findings of the Court in DR-2025-
3118, this cause is hereby dismissed."

On May 21, 2025, the State of Alabama, through the Madison

County District Attorney's Office, filed in the Madison Circuit Court a

petition for a writ of mandamus against Judge Coats and Judge Demos

in case number DC-2025-2191, the criminal case. In its petition, the State

contended that "[t]he District Court (Judge Coats) was without authority

to grant immunity in a PFA hearing without notifying the State" and that

"[t]he District Court (Judge Demos) erroneously relied on Judge Coats'

illegal ruling in dismissing the criminal case." (Emphasis omitted.) The

State requested that the Madison Circuit Court "order the District Court

(Judge Demos) to vacate its order as improperly granted and to hold a

Pretrial Immunity Hearing after providing notice to the State and giving

the State an opportunity to present witnesses and be heard in argument"

and "order the District Court (Judge Coats) to vacate its order granting
10
SC-2025-0493; SC-2025-0535

immunity in this case," "order the District Court (Judge Coats) to

henceforth refrain from holding immunity hearings in PFA cases," "order

the District Court (Judge Coats) to henceforth refrain from holding

immunity hearings in criminal cases where it is not the trial court for

such criminal cases," and "order the District Court (Judge Coats) to

henceforth provide the State notice of such hearings, and an opportunity

to be heard and present witnesses in such cases."

On May 22, 2025, the Madison Circuit Court judge before whom the

State's petition was filed, Judge Donna S. Pate, ordered any answers to

the petition to be filed by May 30, 2025. In a subsequent order, Judge

Pate extended the deadline for answers to June 6, 2025.

On June 6, 2025, Henshaw filed an answer to the State's petition.

In his answer, Henshaw contended that the State had waived any

objection to Judge Demos's dismissal of the criminal case by failing to

object or preserve the issue, that the State lacked standing to challenge

Judge Coats's findings in the PFA case, that the State's arguments failed

on the merits because Judge Coats's order was proper and was supported

by the law and the evidence, and that the State's request to prospectively

restrain Judge Coats's judicial authority was improper and unsupported.

11
SC-2025-0493; SC-2025-0535

Also on June 6, 2025, Judge Coats filed an answer to the State's

petition. In her answer, Judge Coats noted that she "sat on the [PFA]

case as a circuit court judge by virtue of her appointment as a special

circuit court judge dated January 2, 2025." Judge Coats presented several

arguments in response to the State's petition, including that the State

should have appealed Judge Demos's order if it had wanted to properly

challenge it, that the State had not properly invoked the jurisdiction of

the circuit court to challenge anything in the PFA case, and that Judge

Coats had acted with the bounds of her authority, jurisdiction, and

discretion because the stand-your-ground statute "applies in civil cases

such as the PFA case." Judge Demos did not file an answer to the State's

petition.

On June 11, 2025, Judge Pate entered an "Order Granting Petition

for Writ of Mandamus" that provided:

"Upon consideration of the Petition for Writ of
Mandamus filed herein, responses thereto filed by Hon. Linda
Coats and Jordan Henshaw (a non-party herein but defendant
in the underlying cases), and applicable law, it is ORDERED
that the State of Alabama is entitled to the relief requested.
Hon. Linda Coats is ORDERED to vacate that portion of her
May 8, 2025, ORDER entered in DR-2025-3118 granting the
defendant therein, Jordan Henshaw, immunity from criminal
prosecution. This Order has no effect on Judge Coats' denial
of [Williams's] Petition for Protection from Abuse. Hon. Patty
12
SC-2025-0493; SC-2025-0535

Demos is ORDERED to vacate her May 14, 2025, Order of
Dismissal in DC-2025-2191 and to restore that case to her
active docket. She is further ORDERED to conduct an
immunity hearing if requested by [Henshaw]."

(Capitalization in original.)

On July 8, 2025, Judge Coats appealed Judge Pate's June 11, 2025,

order to this Court. On July 22, 2025, Judge Demos entered an order

vacating her May 14, 2025, order and reinstated the criminal case

against Henshaw. On July 23, 2025, Henshaw appealed Judge Pate's

June 11, 2025, order to this Court.

In the PFA case, Williams -- this time represented by counsel --

subsequently filed a postjudgment motion to alter, amend, or vacate

Judge Coats's May 8, 2025, order. Williams contended that she had never

received Henshaw's motion seeking a pretrial immunity hearing. She

also asserted that if a new hearing was granted, she would present

pictures of her injuries that would demonstrate that her injuries were not

received as a result of Henshaw's defending himself. Williams also

contended that the findings in the May 8, 2025, order should be affected

by what had happened in the criminal case, i.e., Judge Demos's having

reinstated the criminal case against Henshaw.

13
SC-2025-0493; SC-2025-0535

On October 20, 2025, Judge Coats entered a postjudgment order

addressing Williams's arguments. First, Judge Coats discounted

Williams's claim that she had no notice of the pretrial immunity hearing

because, she said, Williams had

"never informed the court that she did not have [Henshaw's]
motion for which the hearing was conducted and for which she
fully participated. Further, one of [Henshaw's] witnesses
stated he knew the issue before the court was self-defense.
The court assisted [Williams] with her questions and
patiently listened to all her evidence."

Judge Coats also rejected Williams's contention that photographic

evidence of her injuries could have changed the outcome of the hearing.

Judge Coats explained that Williams

"did not dispute the fact that she was throwing household
objects. [Henshaw] was defending himself from [Williams's]
continuing to throw household objects at him in his house,
after he asked her to leave. The Court very carefully
considered this offer of proof and concludes that a re-trial
would not change the outcome."

Finally, Judge Coats granted the portion of Williams's motion that

concerned the parallel criminal case. Judge Coats's order stated:

"The sentence [in the May 8, 2025, order that stated:] 'As
such, [Henshaw] is entitled to the relief requested of
immunity from criminal prosecution and civil action resulting
from the altercation between the parties, which was the
subject of these proceedings' is WITHDRAWN and the
following sentence is substituted therefore: 'As such,
14
SC-2025-0493; SC-2025-0535

[Henshaw] is entitled to the relief requested of immunity
pursuant to Alabama Code Section 13-3-23 for the force
used.' "

(Capitalization in original.)

II. Standard of Review

"Section 12-22-6, Ala. Code 1975, explicitly authorizes
the appeal of a circuit court's issuance of a writ of mandamus.
Section 12-22-6, provides, in pertinent part:

" 'Appeals may be taken to the appropriate
appellate court from the judgment of the circuit
court on application for writs of certiorari,
supersedeas, quo warranto, mandamus,
prohibition, injunction and other remedial writs as
provided by the Alabama Rules of Appellate
Procedure. ... But this section shall not be
construed as to prevent the presentation of an
issue upon appeal taken after a final
determination of the case.'

"See also Ex parte A.S., 3 So. 3d 842, 845 (Ala. 2008) (citing §
12-22-6 for the proposition that 'an appeal, not a petition for
the writ of mandamus, is the proper avenue for challenging a
circuit court's disposition of a petition for the writ of
mandamus')."

Regions Bank v. Reed, 60 So. 3d 868, 878 (Ala. 2010).

"The circuit court's order issuing a writ of mandamus involves
only questions of law. Therefore, the ... standard of review
[that] applies to ... the petition [is] a de novo standard. See,
e.g., George v. Sims, 888 So. 2d 1224, 1226 (Ala. 2004)
15
SC-2025-0493; SC-2025-0535

(observing in a case in which the plaintiff sought a petition for
mandamus that '[b]ecause the facts are undisputed and we
are presented with pure questions of law, our standard of
review is de novo.')."

Id. at 877.

III. Analysis

"Before we can reach the merits, we must first address this Court's

jurisdiction over these appeals," Davis v. American Pride Props., LLC,

411 So. 3d 1220, 1223 (Ala. 2024), because "jurisdictional matters are of

such magnitude that we take notice of them at any time and do so even

ex mero motu." Nunn v. Baker, 518 So. 2d 711, 712 (Ala. 1987). We first

address jurisdiction over Judge Coats's appeal: appeal number SC-2025-

1. We then address jurisdiction over Henshaw's appeal: appeal

number SC-2025-0535.

A. Appeal Number SC-2025-0493

As to Judge Coats's appeal, the unavoidable fact is that Judge Coats

does not have standing to appeal Judge Pate's order issuing of the writ of

mandamus.

"In 'public-law cases,' such as this case,[7] standing is an
absolute necessity for a court to obtain subject-matter

7"Public-law" cases are cases involving "constitutional or other
challenges to the actions of officials or administrative agencies." Ex parte
16
SC-2025-0493; SC-2025-0535

jurisdiction. See Ex parte BAC Home Loans Servicing, LP,
159 So. 3d 31, 44 (Ala. 2013); State v. Property at 2018
Rainbow Dr., 740 So. 2d 1025, 1028 (Ala. 1999). To determine
whether a party has standing, we employ the test set forth in
Lujan v. Defenders of Wildlife, 504 U.S. 555, 112 S.Ct. 2130,
119 L.Ed.2d 351 (1992). Ex parte Aull, 149 So. 3d 582 (Ala.
2014). Principally, under that test, the plaintiffs must
demonstrate 'an actual, concrete and particularized "injury in
fact" -- "an invasion of a legally protected interest." ' Alabama
Alcoholic Beverage Control Bd. v. Henri-Duval Winery,
L.L.C., 890 So. 2d 70, 74 (Ala. 2003) (quoting Lujan, 504 U.S.
at 560, 112 S.Ct. 2130). An injury in fact must be ' "(a) concrete
and particularized, and (b) 'actual or imminent, not
"conjectural" or "hypothetical." ' " ' Ex parte Alabama Educ.
Television Comm'n, 151 So. 3d 283, 287 (Ala. 2013) (quoting
Lujan, 504 U.S. at 560, 112 S.Ct. 2130)."

Hanes v. Merrill, 384 So. 3d 616, 620-21 (Ala. 2023).

The order issuing the writ of mandamus that Judge Coats has

purported to appeal from was directed at her May 8, 2025, order in the

PFA case. Judge Coats has no personal interest in the outcome of the

PFA case, and she is not supposed to have such an interest in any

BAC Home Loans Servicing, LP, 159 So. 3d 31, 44 (Ala. 2013). The State
filed its petition for a writ of mandamus in the only case to which it was
a party, case number DC-2025-2191, the criminal case that had charged
Henshaw with domestic violence. In that case, Henshaw used Judge
Coats's May 8, 2025, order to challenge the State's domestic-violence
charge based on statutory immunity. In her appeal, Judge Coats
primarily advances arguments that raise questions about the propriety
of the State's filing the petition for a writ of mandamus. Thus, Judge
Coats's appeal of the order issuing the writ of mandamus is undoubtedly
a public-law case.
17
SC-2025-0493; SC-2025-0535

particular portion of her ruling in that case. Indeed, "due process requires

a 'neutral and detached judge in the first instance.' " Concrete Pipe &

Prods. of California, Inc. v. Construction Laborers Pension Tr. for S.

California, 508 U.S. 602, 617 (1993) (quoting Ward v. Village of

Monroeville, 409 U.S. 57, 61-62 (1972)). Even to the extent that Judge

Coats's arguments concerning the propriety of the writ of mandamus

involve the bounds of her authority and jurisdiction as a judge, that does

not constitute a legally protected personal interest because that entails

the powers of her office, not an individualized injury.

" 'Only a party prejudiced or aggrieved by a judgment
can appeal. ... "A party cannot claim error where no adverse
ruling is made against him." ' Alcazar Shrine Temple v.
Montgomery Cty. Sheriff's Dep't, 868 So. 2d 1093, 1094 (Ala.
2003) (quoting Holloway v. Robertson, 500 So. 2d 1056, 1059
(Ala. 1986)). Although we have found no Alabama law on the
specific issue at hand, persuasive authority from other
jurisdictions indicates that, when a respondent judge in a
circuit-court mandamus proceeding is merely a nominal
party, the judge may not appeal. In People v. Recorder's Court
Judge, 66 Mich. App. 315, 316, 239 N.W.2d 185, 185 (1975),
the Michigan Court of Appeals held that 'a judge, who was the
nominal defendant in the circuit court, [is not] an aggrieved
party before [the appellate court] ... who has standing to
appeal an order of superintending control issued by the circuit
court.' See also Bender v. Ragan, 53 Wash. 521, 522, 102 P.

18
SC-2025-0493; SC-2025-0535

427, 428 (1909) (noting that, in mandamus proceedings, 'the
judge of the court is a mere nominal party')."8

Enslen v. Alabama Dep't of Transp., 211 So. 3d 841, 844-45 (Ala. Civ.

App. 2016).

The party potentially prejudiced or aggrieved by Judge Pate's order

issuing the writ of mandamus was Henshaw because the writ caused

Judge Demos to reinstate the criminal case against him. Judge Pate's

conclusion that Judge Coats committed some form of legal error by

proclaiming that Henshaw was immune from criminal prosecution for his

8It is true that in some of our cases judges have sought and received

review from this Court after writs of mandamus had been issued to them.
See, e.g., Ex parte State ex rel. Alabama Policy Inst., 200 So. 3d 495, 511
(Ala. 2015); Ex parte Vance, 900 So. 2d 394 (Ala. 2004); Ex parte Sharp,
893 So. 2d 571 (Ala. 2003); and Ex parte Calhoun, 688 So. 2d 259 (Ala.
1997). However, this Court did not raise the issue of standing in most of
those cases. Moreover, as the Court of Civil Appeals observed in Enslen
v. Alabama Department of Transportation, 211 So. 3d 841, 844 (Ala. Civ.
App. 2016), "none of those cases involve an appeal of a mandamus order
under § 12-22-6[, Ala. Code 1975]." Furthermore, in Ex parte Alabama
Policy Institute, this Court concluded that Judge Enslen had standing
because the issue in that case impacted the ministerial duties of his job
as a probate judge. In short, those cases are distinguishable from Judge
Coats's appeal, an appeal that is more akin to the situation in Enslen in
which the Court of Civil Appeals concluded that Judge Enslen did not
have standing to appeal the Elmore Circuit Court's order issuing a writ
of mandamus directing him to conditionally dismiss a condemnation
action that had been instituted in the probate court by the Alabama
Department of Transportation against two property companies.
19
SC-2025-0493; SC-2025-0535

actions that precipitated the PFA case does not create the kind of injury-

in-fact that provides standing to appeal the order issuing the writ.

In sum, the order issuing the writ of mandamus did not inflict upon

Judge Coats an injury-in-fact to a legally protected interest, and,

therefore, Judge Coats lacks standing to appeal. Therefore, Judge Coats's

appeal, appeal number SC-2025-0493, must be dismissed.9

Moreover, even if Judge Coats had standing to appeal, the portion

of Judge Pate's order that issued a writ of mandamus to Judge Coats was

void. Under the PFAA, the only judges that may entertain a PFA petition

are "[a] circuit court judge, a district court judge appointed as a special

circuit court judge pursuant to law or a district court judge designated by

a written standing order from the presiding circuit court judge to handle

9Judge Coats also has purported to appeal the portion of Judge
Pate's June 11, 2025, order that issued a writ of mandamus to Judge
Demos. If anything, Judge Coats possesses even less grounds for
standing to appeal that portion of Judge Pate's order. The portion of
Judge Pate's order that concerned the criminal case was directed at
Judge Demos, not Judge Coats, and as Judge Coats observes in her own
brief: "Judge Coats presided over the civil matter in DR-2025-3118, while
Judge Demos presided over the criminal matter in DC-2025-2191." Judge
Coats's brief, p. 17. Thus, Judge Coats was not involved in, much less a
party to, case number DC-2025-2191, and Judge Pate's order with respect
to that case did not affect Judge Coats in any way. In other words, Judge
Coats was not a party aggrieved by that order, and she therefore cannot
appeal it.
20
SC-2025-0493; SC-2025-0535

protection from abuse cases." § 30-5-2(2), Ala. Code 1975. As we noted in

the rendition of facts, even though Judge Coats is a Madison County

district-court judge, she had been appointed as a special circuit-court

judge pursuant to law, and it was in that capacity that she entertained

Williams's PFA petition.

"A writ of mandamus is a remedy sought for correcting a
particular ruling by a lower court. ... As this Court explained
in State v. Webber, 892 So. 2d 869 (Ala. 2004):

" '... The petition for a writ of mandamus, if
meritorious, merely prompts the appellate court to
exercise its supervisory power to tell the trial
judge, as an official, as distinguished from the trial
court itself, to do his or her duty when that duty is
so clear that there are no two ways about it. ...'

" 892 So. 2d at 871 (citations omitted)."

Regions Bank, 60 So. 3d at 877 (emphasis added). See also State v.

Maddox, 828 So. 2d 946, 947-48 (Ala. Crim. App. 2001) (" 'Clearly, a writ

of mandamus is a supervisory order; thus, an appellate court may issue

this writ in any situation, within recognized limits, where this writ is

necessary to protect the proper judicial administration of the courts.' "

(citation omitted; emphasis added)).

Judge Pate, as a circuit-court judge, has supervisory jurisdiction

over district courts. See § 12-11-30(4), Ala. Code 1975 ("The circuit court
21
SC-2025-0493; SC-2025-0535

shall exercise a general superintendence over all district courts,

municipal courts, and probate courts."). Thus, Judge Pate has the

authority to issue a writ of mandamus to a district-court judge -- as she

did to Judge Demos -- but she did not have the authority to issue a writ

of mandamus to Judge Coats because Judge Coats was acting as a special

circuit-court judge when she adjudicated the PFA case. Appellate courts

have supervisory jurisdiction over the circuit courts, but circuit courts do

not have supervisory jurisdiction over one another. Cf. Ex parte

Marshall, 323 So. 3d 1188, 1206 (Ala. 2020) (Mendheim, J., concurring

specially, joined by Bolin, Wise, Bryan, and Stewart, JJ.) ("Within their

territorial jurisdictions, the circuit courts have supervisory authority

over inferior tribunals, but the limitations on their jurisdiction

necessarily mean that the circuit courts do not have supervisory

jurisdiction over one another."). Accordingly, in this particular instance,

Judge Pate could not issue a writ of mandamus to Judge Coats because

Judge Pate did not have supervisory jurisdiction over Judge Coats in her

capacity as a special circuit-court judge adjudicating the PFA case.

We note that Judge Pate's error is entirely understandable given:

(1) that Judge Coats's regular office is that of a district-court judge; (2)

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SC-2025-0493; SC-2025-0535

that the State's petition stated that the PFA case "was before Madison

County District Court Judge Linda F. Coats"; and (3) that Judge Coats's

May 8, 2025, order contained the style header "In the District Court of

Madison County, Alabama," and identified her as "District Judge."

Indeed, in these appeals, none of the parties picked up on the effect of the

fact that Judge Coats was sitting as a special circuit-court judge when

she entertained the PFA case.

Regardless, Circuit Judge Pate did not have supervisory authority

to issue a writ of mandamus to Special Circuit Judge Coats.

Consequently, to the extent that Judge Pate's June 11, 2025, order

purported to direct Judge Coats to vacate a portion of her May 8, 2025,

order in the PFA case, Judge Pate's order was void. "[A] void order will

not support an appeal." Beam v. Taylor, 149 So. 3d 571, 577 (Ala. 2014).

Therefore, Judge Coats's appeal of Judge Pate's order is also due to be

dismissed because the appeal stems from a void order.

B. Appeal Number SC-2025-0535

What remains before us is Henshaw's appeal of Judge Pate's June

11, 2025, order. Henshaw has purported to appeal both aspects of Judge

Pate's order, i.e., her issuance of a writ of mandamus to Judge Coats and

23
SC-2025-0493; SC-2025-0535

her issuance of a writ of mandamus to Judge Demos. However, as we

explained in subsection A of this analysis, the portion of Judge Pate's

order that commanded Judge Coats to vacate a portion of her May 8,

2025, order is void and cannot support an appeal. Therefore, we dismiss

the portion of Henshaw's appeal that challenges the writ of mandamus

to Judge Coats.

However, we also noted in subsection A that Judge Pate did have

supervisory jurisdiction to issue a writ of mandamus to District Judge

Demos. Henshaw also has appealed that portion of Judge Pate's June 11,

2025, order, arguing that Judge Pate erred in granting the State's

petition because the State allegedly failed to object to the dismissal of the

criminal case and the State allegedly should have appealed Judge

Demos's order rather than seeking a petition for a writ of mandamus. We

cannot address the merits of Henshaw's arguments, however, because

this Court lacks jurisdiction over that portion of his appeal.

The State argues that both of these appeals belong in the Court of

Civil Appeals because "the appellants have appealed the issuance of a

Writ of Mandamus arising from a domestic relations case (Williams v.

Henshaw, Domestic Relations Case No. DR-2025-3118 (Madison Cnty.))."

24
SC-2025-0493; SC-2025-0535

State's brief, p. 19. The State observes that under § 12-3-10, Ala. Code

1975, " '[t]he Court of Civil Appeals shall have exclusive appellate

jurisdiction of … all appeals in domestic relations cases, including

annulment, divorce, adoption, and child custody cases and all

extraordinary writs arising from appeals in said cases.' " Id. (emphasis

omitted). A PFA proceeding is clearly a domestic-relations case. It carries

a DR case number, the PFAA specifically involves preventing abuse in

family situations, see, e.g., Ala. Code 1975, § 30-5-1 (setting forth the

purposes of the PFAA), and § 30-5-2(7) (defining the term "Victim" in the

PFAA), and every direct appeal we are aware of from a PFA proceeding

-- whether stemming from an independent action or from a divorce or

child-custody dispute -- has been heard by the Court of Civil Appeals.

Additionally, an appeal from an order issuing a writ of mandamus in

relation to a matter as to which a particular court has appellate

jurisdiction belongs in the court that has appellate jurisdiction over such

a matter. See State v. Isbell, 985 So. 2d 446, 449 (Ala. 2007).

Based on the foregoing, the State's argument would be persuasive

in relation to Henshaw's appeal of the portion Judge Pate's order that

pertained to Judge Coats's May 8, 2025, order in the PFA case. However,

25
SC-2025-0493; SC-2025-0535

as we already have explained, that aspect of Henshaw's appeal is due to

be dismissed because it stems from a portion of Judge Pate's order that

is void.

The portion of Judge Pate's order that remains, and as to which

Henshaw has appealed, is the part that ordered Judge Demos to vacate

her May 14, 2025, order in case number DC-2025-2191, and to restore

that case to her active docket. That case, which is the State's action

charging Henshaw with third-degree domestic violence, is a criminal

case. Under § 12-11-30(3) "[t]he circuit court shall have appellate

jurisdiction of ... criminal ... cases in district court ..., except in cases in

which direct appeal to the Court[ ] of ... Criminal Appeals is provided by

law or rule."10 Under § 12-3-9, Ala. Code 1975, the Court of Criminal

10Rule 30.2, Ala. R. Crim. P., provides:

"An appeal from the district or municipal court shall go
directly to the appropriate appellate court:

"(1) If an adequate record or stipulation of
fact is available and the right to a jury trial is
waived by all parties entitled to trial by jury, or

"(2) If the parties stipulate that only
questions of law are involved and the district court
or the municipal court certifies the question."
26
SC-2025-0493; SC-2025-0535

Appeals has "exclusive appellate jurisdiction of all misdemeanors,

including the violation of town and city ordinances, habeas corpus and

all felonies, including all post conviction writs in criminal cases." Thus,

except in special circumstances, an appeal in the criminal case would

belong in the circuit court. But in this instance, Henshaw's appeal stems

from the issuance of a writ of mandamus by the circuit court to the

district court in a criminal matter. " 'The Court of Criminal Appeals has

... a general superintendence and control of the circuit courts in criminal

matters, over which it has exclusive appellate jurisdiction.' " Ex parte

King, 23 So. 3d 77, 79 (Ala. 2009) (quoting Ex parte Nice, 407 So. 2d 874,

876 (Ala. 1981)). See Art. IV, § 141(d), Ala. Const. 2022. Therefore,

Henshaw's appeal belongs in the Court of Criminal Appeals. Cf. Isbell,

985 So. 2d at 449 (concluding that "the Court of Criminal Appeals was

the proper forum for resolution of the dispute made the basis of this

mandamus proceeding because there is a pending criminal proceeding

and any appeal from that proceeding would be to that court").

Based on the foregoing, we transfer Henshaw's appeal, appeal

number SC-2025-0535, challenging Judge Pate's June 11, 2025, order

27
SC-2025-0493; SC-2025-0535

issuing a writ of mandamus to Judge Demos to the Court of Criminal

Appeals.

IV. Conclusion

Judge Coats's appeal, appeal number SC-2025-0493, is dismissed

because Judge Coats lacks standing and because Judge Coats appeals

from a void order. Henshaw's appeal of the portion of Judge Pate's order

that issued a writ of mandamus to Judge Coats is dismissed because that

aspect of his appeal stems from a void order. Henshaw's appeal of the

portion of Judge Pate's order that issued a writ of mandamus to Judge

Demos belongs within the appellate jurisdiction of the Court of Criminal

Appeals. Therefore, we transfer appeal number SC-2025-0535 to the

Court of Criminal Appeals.

SC-2025-0493 -- APPEAL DISMISSED.

SC-2025-0535 -- APPEAL DISMISSED IN PART AND

TRANSFERRED.

Stewart, C.J., and Bryan and McCool, JJ., concur

Shaw, J., concurs in the result.

28