Griffin v. Bentley

Summary

The Alabama Supreme Court granted consolidated petitions for writs of mandamus arising from an inverse-condemnation action involving electronic bingo machines and related property seized during an illegal-gambling investigation. The Court held that the Montgomery Circuit Court lacked subject-matter jurisdiction because the civil action impermissibly interfered with the executive branch’s criminal-law enforcement and related forfeiture proceedings in Mobile County. It directed the Montgomery court to vacate its order requiring the return of the seized property and to dismiss the action.

Holdings

1. The Montgomery Circuit Court lacked subject-matter jurisdiction to interfere by civil action with the executive branch's enforcement of the criminal law, including the seizure and forfeiture proceedings concerning the electronic-bingo machines and related property.
2. Mandamus was appropriate because subject-matter jurisdiction is reviewable by mandamus and the petitioners established a clear legal right to an order vacating the Montgomery Circuit Court's jurisdictional directives and dismissing the Montgomery action.

Questions Presented

1. Whether the Montgomery Circuit Court had subject-matter jurisdiction to adjudicate Griffin's inverse-condemnation action concerning property seized during a criminal investigation into illegal gambling.
2. Whether the temporary storage of the seized property in Montgomery County or Griffin's earlier filing there gave the Montgomery Circuit Court jurisdiction to interfere with the criminal-law enforcement and forfeiture proceedings arising from the Mobile County seizure.
3. Whether the petitions for writs of mandamus should be granted.

Disposition

writ_granted