Hall v. Nelson

Melton, Justice,

dissenting.

“The law is well settled that mandamus relief is available only if the petitioner has a clear legal right to the relief sought and that there is no other adequate legal remedy.” Hall v. Madison, 263 Ga. 73, 74 (428 SE2d 345) (1993). Thus, where the adequate legal remedy of contempt is available to coerce compliance with a prior court order, mandamus is unavailable. See Carey Canada, Inc. v. Hinely, 257 Ga. 150 (356 SE2d 202) (1987) (“criminal contempt [is appropriate for] imposing] unconditional punishment for prior acts of contumacy, whereas civil contempt [is appropriate for] imposing] conditional punishment as a means of coercing future compliance with a prior court order”). Because Division 3 of the majority opinion authorizes the trial court’s inappropriate use of mandamus as a substitute for the adequate legal remedy of contempt to force compliance with a prior order, I must respectfully dissent.

In its October 19, 2005 order, the trial court expressly upheld the State Board of Education’s decision to “order[ ] reinstatement” based on the Atlanta Independent School System’s “fail[ure] to carry its burden of proof.” The October 19 order thus explicitly obligated AISS to reinstate Nelson.

When AISS failed to comply with the October 19 order, the trial court attempted to coerce compliance with the order by granting Nelson’s petition for mandamus. Indeed, as the trial court stated in its December 12, 2006 order granting the mandamus petition, “[t]he Court expected compliance with its Order of October 19, 2005, and demands immediate compliance now.” However, the proper procedure for bringing about compliance was to hold AISS in contempt, not to prematurely grant mandamus where the adequate remedy at law of contempt still existed. See, e.g., Cobb County v. Wilson, 259 Ga. 685 *447(2) (b) (386 SE2d 128) (1989). Because the granting of mandamus here was erroneous, I must dissent.

Decided September 24, 2007. Greenburg Traurig, Rodney G. Moore, Dorsey E. Hopson II, Lawrence Dietrich, for appellant. Kramer & Patel, Michael E. Kramer, Borquaye A. Thomas, for appellee.