State v. Martin, 69 So. 3d 94

Mobile Circuit Judge granted discovery of the Mobile Police Department investigation file in May 2010; the State sought mandamus to vacate the order.
Martin sought Rule 32 discovery claiming exculpatory Brady material; the trial court ordered production of the file.
Court of Criminal Appeals previously granted mandamus relief against discovery of the file, citing procedural bars and good-cause requirements.
Intervening appellate actions: the Court of Criminal Appeals vacated or directed reconsideration based on postconviction standards and jurisdiction issues.
In 2010, the trial court again ordered discovery of the file, finding good cause and facial merit; the State petitioned for mandamus this time to review.
This Court denies mandamus relief, applying Ocwen two-prong standard to postconviction discovery review and overruling prior cases inconsistent with Ocwen.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mandamus is proper review here	State contends mandamus is proper due to discovery denial.	Martin argues ordinary appeal suffices; mandamus not appropriate.	State's mandamus petition denied; not proper avenue.
Whether the trial court independently reviewed the claims	State claims independent review of amended motion occurred.	State contends no independent review or merits considered.	State not entitled to mandamus review; independent review not shown under Ocwen.
Applicability of Ocwen twoprong standard to postconviction discovery	Ocwen should not apply; prior Land/Turner standards control.	Ocwen's two-prong standard applies and requires adequate remedy by appeal.	Ocwen standard applies; petition denied.

Ex parte Ocwen Fed. Bank, FSB, 872 So.2d 810 (Ala. 2003) (mandamus not available where adequate appeal exists)
Ex parte Land, 715 So.2d 847 (Ala. 2000) (good-cause standard for postconviction discovery)
Ex parte Turner, 2 So.3d 806 (Ala. 2008) (discovery review in postconviction cases via mandamus allowed in some contexts)
Ex parte Perkins, 941 So.2d 242 (Ala. 2006) (circuit courts discretionary in postconviction discovery)
Ex parte Wright, 860 So.2d 1253 (Ala. 2002) (postconviction Rule 32 proceedings are civil)