Chandler v. State
Docket: CR-98-2414
Court: Court of Criminal Appeals of Alabama; February 24, 2000; Alabama; State Appellate Court
Mark A. Chandler, Sr. pleaded guilty to murder in Madison County and is currently incarcerated. He filed a habeas corpus petition in Limestone County, arguing for release on several grounds: 1) His arrest warrant for capital murder was improperly issued based on an affiant's conclusions, rendering it void; 2) The robbery charge was invalid as capital murder included the serious physical injury element; 3) His arrest warrant was void because it lacked a judge's or magistrate's signature in an official capacity; and 4) The circuit clerk administrator lacked authority to issue arrest warrants. The Limestone County district attorney moved to dismiss the petition, asserting the claims lacked merit. The circuit court denied the petition, stating that habeas corpus is not the appropriate remedy for trial errors and that Chandler's claims should be treated as a post-conviction relief petition under Rule 32. It ruled that the Limestone Circuit Court lacked authority, as it was not the court of conviction, and should have transferred the petition to Madison County where the conviction occurred. The ruling emphasized that Rule 32 petitions must be filed in the court of conviction, and while a petition improperly labeled may still be affirmed, jurisdictional issues must be respected. Consequently, the circuit court's denial of the habeas corpus petition was reversed, and the case was remanded for transfer to Madison County Circuit Court, which has the authority to address Chandler’s claims under Rule 32.