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The Source of Subject-Matter Jurisdiction: Defining the Court’s Authority through City of Huntsville v. Fearn

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In a case that clarifies the breadth of appellate jurisdiction, the Alabama Court of Criminal Appeals recently heard an appeal originating at the heart of Madison County. This case, City of Huntsville v. Fearn, addresses the source of subject-matter jurisdiction for Alabama courts and the validity of appeals brought before the circuit court alleging a defect in the original charging complaint.

Brodrick D. Fearn, Dillon Barret, Curtis E. Tanner, John Sandifer, and Justin Bell were all charged with violating city ordinances and were convicted in the Huntsville Municipal Court. They each appealed their convictions to the Madison Circuit Court, seeking a de novo jury trial, but the cases never proceeded to trial. The defendants then moved to dismiss the charges against them, alleging defects in each of their charging complaints. The circuit court agreed with their argument and dismissed the charges, leading to this appeal brought by The City of Huntsville.

This appeal consolidated the cases of all five men, raising the issue of subject-matter jurisdiction under §12-11-30(3) of the Alabama Code, which defines the scope of jurisdiction for appellate courts in the state. Under this statute, a circuit court has appellate jurisdiction of cases in district court, as well as prosecutions for ordinance violations in municipal courts, as is the case here. The statute also provides that appeals shall be tried de novo, with or without a jury. Counsel for Fearn and the other defendants argued that, due to defects in the original charging complaints for each defendant, the circuit court lacked subject-matter jurisdiction over the case. Essentially, Fearn argued that the court’s jurisdiction was derived from the charging complaint, and if the complaint itself was faulty, then the court did not have jurisdiction over the case.

The Court reversed the previous dismissal of the charges, finding that a defect in a municipal court complaint is not sufficient to remove a circuit court’s subject-matter jurisdiction over an appeal. The source of subject-matter jurisdiction lies within §12-11-30, and therefore the court’s jurisdiction is not derived from the charging complaint itself. This decision clarifies that arguments regarding defects in charging complaints should be raised in the municipal court. By failing to raise those arguments in the municipal court, the defendants waived their right to bring this argument on appeal.

Although the court ultimately sided with the city, finding the complaints non-defective and recognizing the circuit court’s subject-matter jurisdiction regardless of any such defects, City of Huntsville v. Fearn provides important clarification as to the breadth of circuit court jurisdiction, as well as the proper timing to raise arguments relating to potential defects in a complaint itself.

If you are facing a criminal charge in Alabama, call Joe Ingram or Ingram Law LLC, at 205-335-2640. Get Relief Get Results

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