Jordan Ray Henshaw v. State of Alabama

Henshaw · Supreme Court of Alabama · February 20, 2026 · No. SC-2025-0535

Summary

The Supreme Court of Alabama addresses consolidated appeals arising from a Madison Circuit Court writ of mandamus concerning protection-from-abuse and domestic-violence proceedings involving Jordan Ray Henshaw. The Court dismisses Judge Linda F. Coats's appeal for lack of standing and dismisses Henshaw's appeal in part, transferring it to the Court of Criminal Appeals. The opinion also discusses the authority to conduct a pretrial hearing under Alabama's stand-your-ground immunity statute.

Holdings

  1. Judge Coats lacked standing to appeal the mandamus order because she had no personal, legally protected interest or injury in fact resulting from the order.
  2. A circuit court lacks supervisory jurisdiction to issue a writ of mandamus directing a judge acting as a special circuit judge to vacate an order entered in that capacity.
  3. The mandamus order directing Judge Coats to vacate part of her PFA order was void, and neither Judge Coats's nor Henshaw's appeal from that portion of the order could proceed.
  4. Henshaw's appeal concerning the mandamus order directing District Judge Demos to vacate the dismissal of the criminal case belongs in the Court of Criminal Appeals.

Questions Presented

  1. Whether Judge Coats had standing to appeal the Madison Circuit Court's mandamus order.
  2. Whether the Madison Circuit Court had supervisory jurisdiction to issue a writ of mandamus directing Judge Coats, who was acting as a special circuit judge, to vacate part of her PFA order.
  3. Whether the portion of Henshaw's appeal challenging the mandamus order directed to Judge Coats could proceed when that order was void.
  4. Whether Henshaw's appeal challenging the mandamus order directed to District Judge Demos in the criminal case belonged in the Supreme Court of Alabama or the Court of Criminal Appeals.

Disposition

dismissed

Cases Cited (28)

  • Ex parte A.S., 3 So. 3d 842 (Ala. 2008)(followed)
  • Regions Bank v. Reed, 60 So. 3d 868 (Ala. 2010)(followed)
  • George v. Sims, 888 So. 2d 1224 (Ala. 2004)(followed)
  • Davis v. American Pride Properties, LLC, 411 So. 3d 1220 (Ala. 2024)(followed)
  • Nunn v. Baker, 518 So. 2d 711 (Ala. 1987)(followed)
  • Ex parte BAC Home Loans Servicing, LP, 159 So. 3d 31 (Ala. 2013)(followed)
  • State v. Property at 2018 Rainbow Drive, 740 So. 2d 1025 (Ala. 1999)(followed)
  • Ex parte Aull, 149 So. 3d 582 (Ala. 2014)(followed)
  • Alabama Alcoholic Beverage Control Board v. Henri-Duval Winery, L.L.C., 890 So. 2d 70 (Ala. 2003)(followed)
  • Ex parte Alabama Educational Television Commission, 151 So. 3d 283 (Ala. 2013)(followed)

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