Ex parte Woods

Summary

The Supreme Court of Alabama granted Robert Earl Woods's petition for a writ of mandamus. The court held that his challenge to Alabama Department of Corrections disciplinary sanctions was properly brought as a petition for writ of certiorari, not habeas corpus, because the sanctions did not implicate a liberty interest. It directed the Montgomery Circuit Court to vacate its order converting and transferring the petition, holding that venue was proper in Montgomery County.

Holdings

1. Because the Department of Corrections sanctions did not implicate any liberty interest or restrain a liberty Woods presently enjoyed, his petition could not properly be reviewed as a petition for writ of habeas corpus; the proper vehicle was a petition for writ of certiorari.
2. A petition for writ of certiorari challenging action by the Alabama Department of Corrections should be filed in the Montgomery Circuit Court, where the Department maintains its headquarters; the Montgomery Circuit Court therefore had proper venue and the transfer to St. Clair County was erroneous.
3. Woods established a clear legal right to mandamus relief, and the Supreme Court of Alabama granted the petition and issued the writ directing the Montgomery Circuit Court to vacate its order.

Questions Presented

1. Whether Woods's challenge to the Department of Corrections disciplinary decision was properly brought as a petition for writ of certiorari rather than as a petition for writ of habeas corpus.
2. Whether the Montgomery Circuit Court had the proper venue to hear Woods's certiorari petition against the Department of Corrections.
3. Whether Woods established a clear legal right to mandamus relief directing the Montgomery Circuit Court to vacate its conversion and transfer order.

Disposition

writ_granted