Ex parte Moore and Lloyd, [Ms. SC-2024-0377, Oct. 25, 2024] __ So. 3d __ (Ala. 2024). The Court (Mendheim, J.; Parker, C.J., and Shaw, Wise, Bryan, Sellers, Stewart, Mitchell, and Cook, JJ., concur) issues writs of mandamus and prohibition. Via the writ of mandamus, the Shelby Circuit Court is directed to dissolve an October 4, 2018, stay of execution on a final judgment granting Moore and Lloyd possession of real property. Further, the writ of prohibition restricts further trial proceedings beyond those necessary to enforce or interpret the judgment.
By referring to Alabama precedent that limits the scope and duration of judicial actions of this nature, the Court considers whether the circuit court exceeded its discretion by granting an “immoderate” stay without continued justification. An indefinite stay without sufficient justification is considered “immoderate” and exceeds the trial court’s authority. Ms. *26, citing Ex parte American Family Care, Inc., 91 So. 3d 682, 683 (Ala. 2012). The Court explains that stays should have a limited duration and scope, and trial courts should periodically evaluate whether the grounds for the stay still exist. Additionally, the Court notes that trial courts hold “residual jurisdiction” to interpret, clarify, and enforce their own judgments but that this jurisdiction does not extend to indefinitely halting an already final order. Ms. *29, citing Ex parte Caremark, Rx, LLC, 229 So. 3d 751, 757 (Ala. 2017). Residual jurisdiction is not so broad as to permit substantive modification of unambiguous final judgments. Id., citing George v. Sims, 888 So. 2d 1224, 1227 (Ala. 2004). By granting an indefinite stay, the circuit court prevented enforcement of the final possession order and improperly delayed resolution, violating both finality and judicial efficiency.
The Court concludes that the Shelby Circuit Court’s indefinite stay constituted an abuse of discretion and exceeded the court’s jurisdiction, warranting the issuance of a writ of mandamus to dissolve the stay imposed in the circuit court’s October 4, 2018, order. In addition, the Court issues a writ of prohibition requiring the circuit court to vacate its May 2024 orders, setting this case for trial and restricting the circuit court from issuing orders beyond what is necessary to enforce the judgment and finalize Moore and Lloyd’s possession of the property.