Background
Martinez Orlandis Black, proceeding pro se, petitioned the Fourth Circuit for a writ of mandamus. The petition sought an order directing North Carolina courts to enforce an order issued in Black’s state court proceedings.
The court’s reasoning
The court concluded that mandamus relief is a drastic remedy available only in extraordinary circumstances. The court emphasized that mandamus is available only when the petitioner has a clear right to the relief sought and no other adequate means to attain it. Crucially, the court found it lacks jurisdiction to grant mandamus relief against state officials and lacks jurisdiction to review final state court orders.
Mandamus relief is a drastic remedy and should be used only in extraordinary circumstances.
Cheney v. U.S. Dist. Ct., 542 U.S. 367, 380 (2004)
What it means going forward
The petition for writ of mandamus was denied, leaving the state court order unenforced by federal mandamus relief.