Ex parte Ann Martin PETITION FOR WRIT OF MANDAMUS (In re: Estate of Patricia Martin, an incapacitated person, by and through her guardian, conservator, and next friend, Phillip Williams v. Ann Martin) (Etowah Circuit Court: CV-23-900129).

CourtSupreme Court of Alabama
DecidedAugust 23, 2024
DocketSC-2023-0902
StatusPublished

This text of Ex parte Ann Martin PETITION FOR WRIT OF MANDAMUS (In re: Estate of Patricia Martin, an incapacitated person, by and through her guardian, conservator, and next friend, Phillip Williams v. Ann Martin) (Etowah Circuit Court: CV-23-900129). (Ex parte Ann Martin PETITION FOR WRIT OF MANDAMUS (In re: Estate of Patricia Martin, an incapacitated person, by and through her guardian, conservator, and next friend, Phillip Williams v. Ann Martin) (Etowah Circuit Court: CV-23-900129).) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ex parte Ann Martin PETITION FOR WRIT OF MANDAMUS (In re: Estate of Patricia Martin, an incapacitated person, by and through her guardian, conservator, and next friend, Phillip Williams v. Ann Martin) (Etowah Circuit Court: CV-23-900129)., (Ala. 2024).

Opinion

Rel: August 23, 2024

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 SPECIAL TERM, 2024 _________________________

SC-2023-0902 _________________________

Ex parte Ann Martin

PETITION FOR WRIT OF MANDAMUS

(In re: Estate of Patricia Martin, an incapacitated person, by and through her guardian, conservator, and next friend, Phillip Williams

v.

Ann Martin)

(Etowah Circuit Court: CV-23-900129)

PARKER, Chief Justice.

Ann Martin petitions this Court for a writ of mandamus directing SC-2023-0902

the Etowah Circuit Court to quash its writ of restitution or possession by

which she was evicted from her home. We dismiss the petition.

Facts

On an unknown date, Patricia Martin purchased a house located

next door to her house in Gadsden. Patricia's daughter, Ann Martin,

assisted in the purchase with $30,000 of her own money. Ann allegedly

had an oral agreement with her parents that she would live in the house

to be near them and assist them as their ages advanced. Ann lived in the

house without a lease and without paying any rent until 2023. She

allegedly assisted with the care of her father until his death and assisted

with the care of her mother until October 2023.

In 2021, Patricia was adjudicated incapacitated. Phillip Williams

was appointed as her guardian and conservator. In June 2022, Williams

repeatedly and unsuccessfully requested that Ann enter into a

residential lease agreement for the house. In 2023, Williams sued Ann on

Patricia's behalf in his capacity as Patricia's guardian, conservator, and

next friend, asserting claims for ejectment and damages for waste, loss

of income, and fraud. After some time and litigation, Williams moved for,

and the circuit court granted, a partial summary judgment as to the claim

2 SC-2023-0902

for ejectment and immediate possession. The circuit court did not

adjudicate any of the claims for damages that were before it.

On October 25, 2023, the circuit court issued a writ of restitution or

possession to the Sheriff of Etowah County, directing him to evict Ann.

Ann filed a motion for an extension of time on October 26, but the circuit

court denied it, and Ann was evicted on October 27. On November 15,

Ann filed a motion to quash the writ of restitution or possession. The

circuit court denied that motion. Ann petitioned this Court for mandamus

review on December 5, 2023. She did not file any motion to stay the

litigation during the pendency of her petition before this Court.

Because Ann did not file any motion to stay litigation during the

pendency of her petition, the lawsuit proceeded in the circuit court. After

Ann filed her petition, Williams petitioned the circuit court for leave to

sell the house. The circuit court granted that petition, and Williams sold

the house as part of a larger property sale on June 28, 2024. On July 11,

2024, Williams, on Patricia's behalf, filed in this Court a motion to

dismiss Ann's petition on the ground that it is moot.

Standard of Review

3 SC-2023-0902

" '[M]andamus is an extraordinary remedy and requires a showing that there is: "(1) a clear legal right in the petitioner to the order sought; (2) an imperative duty upon the respondent to perform, accompanied by a refusal to do so; (3) the lack of another adequate remedy; and (4) the properly invoked jurisdiction of the court." ' "

Ex parte Inverness Constr. Co., 775 So. 2d 153, 156 (Ala. 2000) (citations

omitted). However, this Court may not grant a petition seeking the

extraordinary writ of mandamus if the issue raised is moot. Ex parte

Merrill, 264 So. 3d 855, 861 (Ala. 2018); see also Arrington v. State ex rel.

Parsons, 422 So. 2d 759, 760 (Ala. 1982) ("This Court has often said that,

as a general rule, it will not decide questions after a decision has become

useless or moot.").

Discussion

Williams filed a motion to dismiss, alleging that the controversy has

been rendered moot by the sale of the house. He argues that, because Ann

can no longer be restored to possession of the house, this Court cannot

reach the merits.

"A case is moot when there is no real controversy and it seeks to

determine an abstract question which does not rest on existing facts or

rights." State ex rel. Eagerton v. Corwin, 359 So. 2d 767, 769 (Ala. 1977).

4 SC-2023-0902

" ' "The general rule is, if[,] pending an appeal, an event occurs which renders it impossible for the appellate court to grant any relief, the appeal may be dismissed. ... The condition may ... arise from the act of the court a quo, that is to say, from some order or judgment in the case pending the appeal, which is made by the court, which renders the determination of the questions presented by the appeal unnecessary." ' "

Siegelman v. Alabama Ass'n of Sch. Bds., 819 So. 2d 568, 575 (Ala.

2001) (quoting Caldwell v. Loveless, 17 Ala. App. 381, 382, 85 So. 307,

307-08 (1920)) (emphasis omitted); see also Corwin, 359 So. 2d at 769

("[W]here an event occurs which renders a case moot prior to this court

considering the appeal it will be dismissed because a decision is not

necessary."). Mootness principles apply in mandamus proceedings. See,

e.g., Ex parte Hall, 326 So. 3d 1044, 1045 (Ala. 2020) (dismissing as moot

a mandamus petition filed after the circuit court had vacated the order

at issue); Ex parte Merrill, 264 So. 3d at 861 (holding that a mandamus

petition was moot as to a preliminary injunction regarding an election

that had already occurred); Ex parte Novartis Pharms. Corp., 991 So. 2d

1263, 1271 (Ala. 2008) (dismissing as moot a mandamus petition after

the petitioner challenging a consolidation order received a separate trial).

5 SC-2023-0902

Ann's petition challenges only the writ of restitution or possession

issued by the circuit court. She does not challenge the underlying partial

summary judgment on the ejectment claim. Even if this Court were to

decide that the writ of restitution or possession was unlawful, we would

be unable to accord Ann any relief on that ground. We cannot reverse the

partial summary judgment or the subsequent order granting the petition

to sell the property because neither of those orders, which could be

properly challenged on appeal, have been challenged in Ann's petition.

Ex parte Professional Bus. Owners Ass'n Comp. Fund, 867 So. 2d 1099,

1101 (Ala. 2003) (noting that, "[g]enerally, an appellate court is limited

to considering only those issues raised on appeal").

In response to the motion to dismiss, Ann makes three main

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Related

Ex Parte Inverness Construction Company
775 So. 2d 153 (Supreme Court of Alabama, 2000)
Ex Parte Prof. Bus. Owners Ass'n Wkrs. Comp. Fund
867 So. 2d 1099 (Supreme Court of Alabama, 2003)
Ex Parte Novartis Pharmaceuticals Corp.
991 So. 2d 1263 (Supreme Court of Alabama, 2008)
State Ex Rel. Eagerton v. Corwin
359 So. 2d 767 (Supreme Court of Alabama, 1977)
Arrington v. State Ex Rel. Parsons
422 So. 2d 759 (Supreme Court of Alabama, 1982)
Governor Siegelman v. Alabama Assn., S. Bds.
819 So. 2d 568 (Supreme Court of Alabama, 2001)
Ex Parte State
921 So. 2d 450 (Supreme Court of Alabama, 2005)
Caldwell v. Loveless
85 So. 307 (Alabama Court of Appeals, 1920)
Aliant Bank v. Carter
197 So. 3d 981 (Supreme Court of Alabama, 2015)

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Ex parte Ann Martin PETITION FOR WRIT OF MANDAMUS (In re: Estate of Patricia Martin, an incapacitated person, by and through her guardian, conservator, and next friend, Phillip Williams v. Ann Martin) (Etowah Circuit Court: CV-23-900129)., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ex-parte-ann-martin-petition-for-writ-of-mandamus-in-re-estate-of-ala-2024.