Jurisdictional and Substantive Limits on ASORCNA Relief: Civil-Filing Requirement and Exclusion of Custodial Sexual Misconduct

Introduction

In Briana Marquise Matthews v. State of Alabama, 2025 WL ____ (Ala. Apr. 25, 2025), the Alabama Supreme Court addressed two consolidated appeals arising from petitions by a former prison guard, Briana Matthews, seeking relief from the registration, notification, residency, and employment requirements imposed by the Alabama Sex Offender Registration and Community Notification Act (“ASORCNA”). The two appeals—SC-2024-0447 (from the criminal action) and SC-2024-0480 (from the civil action)—raise threshold questions of appellate jurisdiction and the substantive scope of ASORCNA’s relief provisions. Chief Justice Stewart delivered the opinion, dismissing SC-2024-0447 for lack of jurisdiction and affirming SC-2024-0480 on the merits.

Summary of the Judgment

Appeal SC-2024-0447 (criminal docket) was dismissed. The Court held that, under ASORCNA §§ 15-20A-24 and 15-20A-25, post-sentencing petitions for relief must be filed as civil actions. A petition filed in a completed criminal action is void and cannot support an appeal.
Appeal SC-2024-0480 (civil docket) was affirmed. The circuit court had correctly denied Matthews’s petition for relief from the registration, notification, and residency requirements under § 15-20A-24 because her conviction for custodial sexual misconduct (§ 14-11-31, Ala. Code 1975) is not among the specific offenses listed in § 15-20A-24(a). Her petition under § 15-20A-25 for relief from employment restrictions was granted and is not challenged on appeal.

Analysis

1. Precedents Cited

State v. Biddle, 187 So. 3d 1122 (Ala. 2015): Held that petitions under ASORCNA § 15-20A-23 filed in a completed criminal action were civil in nature and void for lack of jurisdiction.
Ex parte Smith, 438 So. 2d 766 (Ala. 1983): Confirmed that appellate courts must consider subject-matter jurisdiction sua sponte.
Faith Props., LLC v. First Com. Bank, 988 So. 2d 485 (Ala. 2008) and Ex parte Gilmer, 64 Ala. 234 (1879): Defined “final judgment” for appellate purposes as one that leaves nothing further to be done in the trial court.
Ex parte Fontaine Trailer Co., 854 So. 2d 71 (Ala. 2003): Reaffirmed that the legislature is presumed aware of existing law when enacting statutes.
Ex parte Ankrom, 152 So. 3d 397 (Ala. 2013) and Ex parte Pratt, 815 So. 2d 532 (Ala. 2001): Emphasized that courts apply the plain meaning of statutory language unless ambiguous.
Ex parte Cook, 202 So. 3d 316 (Ala. 2016): Recognized ASORCNA-style civil proceedings as within this Court’s jurisdiction.
Liberty Nat’l Life Ins. Co. v. University of Alabama Health Servs. Found., 881 So. 2d 1013 (Ala. 2003): Authorized affirmance on any valid legal ground.

2. Legal Reasoning

The Court’s analysis proceeded in two parts:

A. Jurisdictional Ruling (SC-2024-0447 Dismissed)

ASORCNA §§ 15-20A-24(c)(1) and 15-20A-25(a) require that petitions filed after sentencing be filed in the civil division of the circuit court. Matthews’s petition in the criminal docket was therefore void for lack of subject-matter jurisdiction.
The trial court’s orders in the criminal case, having been entered without jurisdiction, are void and cannot support appellate review. This follows State v. Biddle and related authority.

B. Substantive Ruling (SC-2024-0480 Affirmed)

Section 15-20A-24(a) enumerates the only offenses for which a convicted sex offender may petition for relief from registration, notification, and residency requirements. Custodial sexual misconduct under § 14-11-31 is not among them.
The statute’s plain language is unambiguous. Under well-settled rules of statutory construction, the Court refused to expand relief to unlisted offenses such as custodial sexual misconduct.
Even if custodial sexual misconduct were included, Matthews’s petition was premature: § 15-20A-24(a)(4) permits petitions only at disposition, sentencing, completion of probation, or completion of the ordered registration term. Matthews filed during her probationary period.

3. Impact

This decision clarifies two critical points for practitioners and petitioners under ASORCNA:

Civil-Filing Requirement: Any post-sentence request for relief from ASORCNA must be brought in the civil division. Criminal-docket filings are void and unreviewable.
Narrow Petitioner Eligibility: Relief under § 15-20A-24 is strictly limited to the sex offenses listed in subsection (a). Custodial sexual misconduct is not eligible, reaffirming the legislature’s deliberate choice to exclude it.

The ruling reinforces judicial deference to the statute’s plain terms and directs litigants seeking broader relief to the legislative process.

Complex Concepts Simplified

ASORCNA (Alabama Sex Offender Registration and Community Notification Act): A statutory scheme requiring convicted sex offenders to register, notify agencies, and abide by residency and employment restrictions.
Final Judgment: A court order that fully resolves all claims and leaves nothing for further action in the trial court; only final judgments support direct appeals.
Subject-Matter Jurisdiction: The court’s power to hear and decide a particular category of cases (civil vs. criminal); lacking such jurisdiction renders orders void.
Clear and Convincing Evidence: A standard requiring the petitioner to prove that the contested facts are highly probable or reasonably certain.
Custodial Sexual Misconduct (§ 14-11-31): A Class C felony involving sexual activity by a corrections employee with an inmate. Although a “sex offense” under ASORCNA’s registration definitions, it is not one of the offenses enumerated for relief under § 15-20A-24.

Conclusion

Briana Marquise Matthews v. State of Alabama affirms the principle that statutory relief provisions must be applied according to their express terms, both procedurally and substantively. The Supreme Court of Alabama dismissed the appeal from the criminal docket for lack of jurisdiction—reinforcing that post-sentencing petitions under ASORCNA belong in the civil court—and affirmed the civil-docket judgment denying relief from registration, notification, and residency requirements because custodial sexual misconduct is not among the offenses eligible for such relief. The decision underscores the judiciary’s role in faithfully applying unambiguous statutes and directs any expansion of relief to the legislative branch.