In re: Janae Mitchell v. Melester Ford

CourtCourt of Civil Appeals of Alabama
DecidedJuly 17, 2026
DocketCL-2026-0005
StatusPublished

This text of In re: Janae Mitchell v. Melester Ford (In re: Janae Mitchell v. Melester Ford) is published on Counsel Stack Legal Research, covering Court of Civil Appeals of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: Janae Mitchell v. Melester Ford, (Ala. Ct. App. 2026).

Opinion

Rel: July 17, 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 published in Southern Reporter.

ALABAMA COURT OF CIVIL APPEALS SPECIAL TERM, 2026 _________________________

CL-2026-0005 _________________________

Ex parte Melester Ford

PETITION FOR WRIT OF MANDAMUS

(In re: Janae Mitchell

v.

Melester Ford)

(Dallas Circuit Court: CV-25-900116)

PER CURIAM.

Melester Ford has filed a petition for the writ of mandamus asking

this court to compel the Dallas Circuit Court to vacate certain

interlocutory orders entered against him and to dismiss the underlying CL-2026-0005

case for lack of subject-matter jurisdiction. For the reasons stated below,

we grant the petition in part and deny it in part.

Background

On February 19, 2025, Ford filed a three-count complaint against

Janae Mitchell in the Dallas District Court ("the district court"). In the

first count, Ford alleged that Mitchell had breached a contract between

the parties in which Mitchell had "agreed to purchase [a] mobile home

for $7,000 at the rate of $147.12 per month, to pay a lot fee, provide

insurance, and pay the yearly state registration fees for the mobile home

...." In the second count, Ford stated a "replevin" claim seeking return of

the mobile home to him. In the third count, Ford alleged that he was the

owner of the lot upon which the mobile home sat, that Mitchell had failed

to pay the lot-rental fee, and that he had provided Mitchell with written

notice that her right to possession of the lot had been terminated; he

demanded possession of the lot and requested an award of $11,166.12 in

unpaid rent and late fees.

Mitchell did not appear for trial, and, on March 14, 2025, the

district court entered a judgment ("the district-court judgment") in favor

of Ford on all three counts, evicting Mitchell from the lot, awarding

2 CL-2026-0005

possession of the mobile home and the mobile-home lot to Ford, and

awarding Ford the requested damages. On March 20, 2025, Mitchell,

acting pro se, filed a postjudgment motion by letter, and, on April 11,

2025, after a hearing, the district court entered an order denying the

motion. On April 25, 2025, Mitchell appealed the district-court judgment

to the Dallas Circuit Court ("the circuit court").

On October 29, 2025, Ford failed to appear for trial, as scheduled

by the circuit court, and the circuit court entered an order in favor of

Mitchell ("the circuit-court order") in which it awarded her possession of

the mobile home and set a hearing to assess damages. On November 24,

2025, Ford filed a motion to vacate the circuit-court order, arguing that

he had failed to appear for the trial because he had not been notified of

the trial setting. On December 2, 2025, Ford filed a motion to dismiss

the case, arguing that the circuit court did not have subject-matter

jurisdiction over the case because Mitchell had not timely appealed the

district-court judgment. On December 3, 2025, the circuit court heard

oral arguments on those motions, and the circuit-court judge indicated

that the motions would be denied. Following the hearing, Ford filed a

motion labeled as a Rule 60(b)(4), Ala. R. Civ. P., motion to vacate the

3 CL-2026-0005

circuit-court order as void.1 Later that day, the circuit court entered

written orders denying all of Ford's pending motions.

On January 7, 2026, Ford filed a petition for the writ of mandamus

in this court.

Issue

In the petition, Ford argues that the circuit court never acquired

subject-matter jurisdiction over the underlying case because, he says,

Mitchell did not timely appeal the district-court judgment. Ford

maintains that the circuit-court order is void and that this court should

direct the circuit court to vacate that order and to dismiss the case.

Standard of Review

A petition for the writ of mandamus is a proper vehicle to review an

interlocutory order denying a motion to dismiss and a motion to vacate

for lack of subject-matter jurisdiction. See Ex parte Johnson, 715 So. 2d

1Because the circuit-court order was not a final judgment, leaving

the case open for further proceedings to assess damages, see Lucky v. Deutsche Bank Nat'l Tr. Co., 46 So. 3d 966, 967 (Ala. Civ. App. 2009), Rule 60(b)(4), Ala. R. Civ. P., did not apply. See generally Ford Motor Credit Co. v. Carmichael, 383 So. 2d 539 (Ala. 1980) (holding that Rule 60(b) applies only to final judgments and not to interlocutory orders). 4 CL-2026-0005

783 (Ala. 1998). We apply the following standard of review to Ford's

petition:

" 'Mandamus is a drastic and extraordinary writ, to be issued only where 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) properly invoked jurisdiction of the court.' "

Ex parte Perfection Siding, Inc., 882 So. 2d 307, 309-10 (Ala. 2003)

(quoting Ex parte Integon Corp., 672 So. 2d 497, 499 (Ala. 1995)).

Analysis

Ford argues that the time for appealing the district-court judgment

was governed by Ala. Code 1975, § 35-9A-461(d), a part of the Alabama

Uniform Residential Landlord and Tenant Act ("the AURLTA"), Ala.

Code 1975, § 35-9A-101 et seq. The AURLTA applies to residential

landlord-tenant relationships. Ala. Code 1975, § 35-9A-102(c). The

AURLTA recognizes that a residential landlord may maintain an action

against a tenant for eviction in a district court. Ala. Code 1975, § 35-9A-

461(a) and § 35-9A-141(a)(5). Upon the entry of a final eviction judgment,

any party aggrieved by the judgment may appeal to the appropriate

circuit court. See generally Radcliff v. Hall Hous. Invs., Inc., 47 So. 3d

1258, 1262 (Ala. Civ. App. 2010).

5 CL-2026-0005

"Notwithstanding subsection (a) of [Ala. Code 1975, §] 12-12- 70, any party may appeal from an eviction judgment entered by a district court to the circuit court at any time within seven days after the entry thereof. The filing of a timely post- judgment motion pursuant to the Alabama Rules of Civil Procedure shall suspend the running of the time for filing a notice of appeal. In cases where post-judgment motions are filed, the full time fixed for filing a notice of appeal shall be computed from the date of the entry in the civil docket of an order granting or denying such motion, or the date of the denial of such motion by operation of law pursuant to Rule 59.1 of the Alabama Rules of Civil Procedure."

§ 35-9A-461(d).

Ford notes that Mitchell filed a postjudgment motion within six

days of the entry of the March 14, 2025, district-court judgment, which

the district court adjudicated by entering an order denying the motion on

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