Ex parte C.M. (In re: State of Alabama v. C.M.) (Cleburne Circuit Court: CC-22-335)

CourtCourt of Criminal Appeals of Alabama
DecidedAugust 23, 2024
DocketCR-2023-0434
StatusPublished

This text of Ex parte C.M. (In re: State of Alabama v. C.M.) (Cleburne Circuit Court: CC-22-335) (Ex parte C.M. (In re: State of Alabama v. C.M.) (Cleburne Circuit Court: CC-22-335)) is published on Counsel Stack Legal Research, covering Court of Criminal Appeals 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 C.M. (In re: State of Alabama v. C.M.) (Cleburne Circuit Court: CC-22-335), (Ala. Ct. App. 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 published in Southern Reporter.

Alabama Court of Criminal Appeals OCTOBER TERM, 2023-2024 _________________________

CR-2023-0434 _________________________

Ex parte C.M.

PETITION FOR WRIT OF CERTIORARI

(In re: State of Alabama

v.

C.M.)

(Cleburne Circuit Court, CC-22-335)

COLE, Judge.

C.M.1 asks this Court -- in what she styled as a petition for a writ

of mandamus -- to direct the circuit court to vacate its judgment denying

1Due to the nature of this petition, initials are used to protect the

petitioner's anonymity. See Rule 52, Ala. R. App. P. CR-2023-0434

her request to have her two guilty-plea convictions for second-degree

assault expunged under § 15-27-2, Ala. Code 1975. C.M. argues that,

because she committed those crimes while she was a victim of human

trafficking, her convictions are "eligible for expungement under § 15-27-

2(a) and (b)." (C.M.'s petition, pp. 11-12.) However, the plain language

of § 15-27-2(a) and (b), Ala. Code 1975, does not allow for C.M.'s second-

degree-assault convictions to be expunged. For the following reasons, we

deny the writ.

C.M.'s Petition and the Standard of Review

Although she styled her filing in this Court as a petition for a writ

of mandamus, a mandamus petition is not the mechanism by which to

challenge a circuit court's judgment under § 15-27-2. Section 15-27-5(c)

makes it clear that "[t]he ruling of the court shall be subject to certiorari

review." (Emphasis added). Thus, C.M.'s petition challenging the circuit

court's judgment denying her request to expunge her criminal convictions

is, in substance, a petition for a writ of certiorari, not a petition for a writ

of mandamus.

C.M.'s mislabeling of her petition is not fatal to her petition or to

this Court's review of her petition. Rather, this Court is duty-bound to

2 CR-2023-0434

"treat an action according to its substance and not its style." Cook v.

Alabama Dep't of Corr., [Ms. CR-2022-0927, May 3, 2023] ___ So. 3d ___,

___ (Ala. Crim. App. 2023) (citing Ex parte Deramus, 882 So. 2d 875 (Ala.

2002)). Thus, we treat C.M.'s petition for a writ of mandamus as a

petition for a writ of certiorari. 2

In so doing, we recognize that we will not reverse the circuit court's

judgment in this case "absent a showing of an abuse of discretion." § 15-

2We recognize that in both Bell v. State, 217 So. 3d 962 (Ala. Crim.

App. 2016), and Levins v. State, 285 So. 3d 250 (Ala. Crim. App. 2016), this Court dismissed the direct appeals filed by Bell and Levins from the circuit courts' judgments denying their motions to expunge their records, and, in those cases, this Court did not treat their filings according to their substance. In those cases, however, this Court explained that their appeals had to be dismissed because there existed no statutory right to file a notice of appeal from the judgments, and that a petition for a writ of certiorari is governed by Rule 21(c), Ala. R. App. P.

Here, unlike in Bell and in Levins, C.M. did not file a notice of appeal challenging the circuit court's judgment. She filed a petition for a writ of mandamus under Rule 21(a), Ala. R. App. P. Because a petition for a writ of certiorari filed under Rule 21(c) must "conform, so far as it is practicable, to the procedure prescribed [for writs of mandamus] in subdivisions (a) and (b) of" Rule 21, C.M. properly invoked the supervisory jurisdiction of this Court to issue a remedial writ, even though she mislabeled her petition. See Ex parte Nice, 407 So. 2d 874, 876 (Ala. 1981) ("The Court of Criminal Appeals has authority to issue such remedial and original writs as are necessary to give it a general superintendence and control of the circuit courts in criminal matters, over which it has exclusive appellate jurisdiction."). 3 CR-2023-0434

27-5(c), Ala. Code 1975. Furthermore, " ' "[a] judge abuses his discretion

only when his decision is based on an erroneous conclusion of law or

where the record contains no evidence on which he rationally could have

based his decision." ' " Ex parte Khouly, 332 So. 3d 938, 940 (Ala. Crim.

App. 2021) (quoting Ex parte Steinberg, 294 So. 3d 835, 838 (Ala. Crim.

App. 2019), quoting in turn Albarran v. State, 96 So. 3d 131, 198 (Ala.

Crim. App. 2011)).

Facts and Procedural History

On November 7, 2022, C.M. filed in the Cleburne Circuit Court a

"Petition For Expungement," in which she alleged that, on May 15, 2015,

while she was a victim of human trafficking, she committed, and was

later convicted of, several criminal offenses, including two counts of

second-degree assault.3 (C.M.'s petition, Appendix Vol. 1, Tab A.) C.M.

alleged that "[t]he offenses she committed in the State of Alabama would

not have occurred but for the fact that she was being trafficked." (Id.)

3C.M. alleged that she had also been convicted of resisting arrest,

unlawful possession of drug paraphernalia, unlawful possession of a controlled substance, and first-degree receiving stolen property, and she asked the circuit court to expunge her convictions as to those offenses. As explained below, however, C.M.'s convictions for these offenses are not before this Court in this petition. Thus, we do not address them. 4 CR-2023-0434

Along with her petition for expungement, C.M. also filed a

"Modified Form CR-65," which is titled "Petition For Expungement of

Records (Section 15-27-1 et seq., Ala. Code 1975)," for her second-degree-

assault convictions. (C.M.'s petition, Appendix Vol. 1, Tab A, Exhibits B

and E.) On those forms, C.M. checked that she was seeking expungement

under "Section IV," which provides as follows:

"[] I, the above-named Defendant/Petitioner, was convicted of the above-named offense, which is one of the following violent felony offenses as defined in Section 12-25- 32, and can show that the commission of the violent felony occurred while I was being trafficked, and would not have been committed but for being trafficked. If you cannot prove this to the court, the conviction for any violent felony below is not eligible for expungement:

"- Promoting prostitution in the first degree pursuant to Section 13A-12-111.

"- Domestic violence in the third degree pursuant to subsection (d) of Section 13A-6-132.

"- Production of obscene matter involving a person under the age of 17 years pursuant to Section 13A-12-197;

"- If none apply, this conviction is not eligible for expungement."

(C.M.'s petition, Appendix Vol. 1, Tab A, Exhibits B and E (emphasis in

original).)

5 CR-2023-0434

On December 20, 2022, the State objected to C.M.'s petition for

expungement. (C.M.'s petition, Appendix Vol. 2, Tab C.) In its objection,

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Related

Ex Parte Jackson
614 So. 2d 405 (Supreme Court of Alabama, 1993)
League of Women Voters v. Renfro
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407 So. 2d 874 (Supreme Court of Alabama, 1981)
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Bell v. State
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Albarran v. State
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Opinion of the Justices
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Ex parte C.M. (In re: State of Alabama v. C.M.) (Cleburne Circuit Court: CC-22-335), Counsel Stack Legal Research, https://law.counselstack.com/opinion/ex-parte-cm-in-re-state-of-alabama-v-cm-cleburne-circuit-court-alacrimapp-2024.