The Alabama Court of Civil Appeals has navigated a complex custody dispute, resulting in the dismissal of most of the mother’s appeal while simultaneously treating a key jurisdictional challenge as a petition for a writ of mandamus, which was ultimately denied. The case centers on custody of a child, A.R., initially held by the mother, Ra’Drecia Reynolds, and sought by the father, Barry Adereti, through the Shelby Circuit Court.
The appellate court’s decision, issued on December 19, 2025, highlights the fine line appellate courts walk between adhering to procedural rules—like the requirement for a final judgment—and ensuring judicial efficiency when fundamental jurisdiction is questioned.
The Circuit Court Battle: Custody Changes and Unresolved Contempt
The legal saga began in November 2022 when the father filed a petition in the Shelby Circuit Court seeking custody, alleging the mother was violating an informal parenting agreement from August 2019. The mother counterclaimed, seeking to terminate the father’s parental rights—a claim the circuit court later acknowledged it lacked jurisdiction over, as termination generally falls under the juvenile court’s purview.
Throughout the pretrial phase, the father pressed for visitation. In April 2024, the circuit court granted him temporary (pendente lite) visitation. Following a November 2024 trial, the court issued a significant order on February 5, 2025. This order modified custody, awarding the parties joint legal custody, but granting the father sole physical custody, subject to the mother’s visitation rights. The court found the father met the necessary legal standards for modification, including the “best interest of the child” standard.
Crucially, the father had filed a motion in January 2025 asking the court to hold the mother in contempt for violating the April 2024 visitation order. However, the February 2025 order, while addressing custody, explicitly noted that the contempt issue was “not properly before the court” at that time.
Following the February order, both parties filed post-judgment motions. The mother argued the father failed to meet the custody modification standard. The father requested amendments, including supervised visitation for the mother and permission to record the child’s phone calls with her. The court granted the father’s requests the same day they were filed (March 7, 2025). The mother appealed after her final challenges were denied in April 2025.
The Final Judgment Hurdle
The Alabama Court of Civil Appeals immediately flagged a critical procedural issue: whether the February 5, 2025, order was a “final judgment.”
The court cited established precedent stating that a judgment is not final if it fails to dispose of *all* claims and controversies between the parties. Since the father’s contempt motion remained unresolved when the circuit court issued its custody order, the appellate court concluded that the February 2025 order was nonfinal.
Because the order was not final, the court determined it must dismiss the appeal concerning the merits of the custody modification and the evidence considered post-trial. These issues, the judges noted, are only reviewable after a true final judgment is entered.
Jurisdiction Question Treated as Mandamus
However, the court exercised its discretion to treat one part of the mother’s appeal—her argument that the circuit court lacked subject-matter jurisdiction over the initial custody petition—as a petition for a writ of mandamus.
The judges explained that addressing jurisdiction immediately serves the interests of judicial economy and prevents the potential for the circuit court to issue a void judgment. A writ of mandamus is an extraordinary remedy, but it is appropriate when a court acts outside its authority.
Circuit Court Retains Concurrent Authority
The mother’s core jurisdictional argument was that because the child had previously been the subject of a dependency action in the juvenile court (between 2016 and 2017), the juvenile court retained exclusive and continuing jurisdiction, stripping the circuit court of the authority to modify custody.
The appellate court rejected this argument by referencing the inherent power of circuit courts in equity matters. Citing previous rulings, the court confirmed that while juvenile courts have exclusive original jurisdiction over dependency cases, this does not deprive circuit courts of *concurrent* subject-matter jurisdiction over child custody matters under general Alabama law.
The court highlighted that the circuit court’s authority stems from its general power to make custody determinations when a child is before it, regardless of whether the juvenile court has formally terminated its own continuing jurisdiction. A prior case involving unmarried parents in a similar situation (J.N.T. v. T.T.S.) supported this conclusion.
Therefore, the Court of Civil Appeals denied the mother’s petition for a writ of mandamus, affirming that the circuit court acted within its jurisdiction when it heard the father’s custody request.
In summary, the mother’s challenge to the circuit court’s authority to hear the case was denied. However, the bulk of her appeal concerning the merits of the custody modification and the post-trial rulings was dismissed, pending a final order from the circuit court that resolves every outstanding issue, including the father’s earlier contempt motion.