4th Cir.

In re MARTINEZ ORLANDIS BLACK

April 27, 2026 ·25-2441 ·Per Curiam · By Maria Santos

The Fourth Circuit denied a pro se petition for a writ of mandamus seeking to compel North Carolina state courts to enforce a prior state order. The court held that federal courts lack jurisdiction to issue mandamus relief against state officials or to review final state court orders.

Martinez Orlandis Black, proceeding pro se, filed a petition for a writ of mandamus in the Fourth Circuit. Black sought an order directing North Carolina state courts to enforce an order that had been issued in his state court proceedings. The petition was directed to the United States District Court for the Western District of North Carolina. Black asked the federal appellate court to intervene and compel the state judiciary to act, effectively seeking federal oversight of a state court's enforcement of its own prior order.

The court issued an unpublished per curiam opinion denying the petition. The court explained that mandamus is a drastic remedy reserved for extraordinary circumstances. To qualify for such relief, a petitioner must demonstrate a clear right to the relief sought and show that they have no other adequate means to attain that relief. The court cited precedent establishing that the Fourth Circuit lacks jurisdiction to grant mandamus relief against state officials. Furthermore, the court noted that it lacks jurisdiction to review final state court orders. Because the relief Black sought fell outside the scope of federal jurisdiction, the court concluded that mandamus was not an available avenue for his request.

The petition is denied, leaving the North Carolina state court order unenforced by federal mandate. The decision reinforces the jurisdictional boundary preventing federal courts from intervening in state court proceedings via mandamus. No further federal action is available on this specific petition, and the matter remains within the state court system.