Rel: December 8, 2023

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern 

Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 

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SUPREME COURT OF ALABAMA

OCTOBER TERM, 2023-2024

_________________________

SC-2023-0507

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Gatewood A. Walden

v. 

The Disciplinary Board of the Alabama State Bar

Appeal from Montgomery Circuit Court

(CV-23-70)

SELLERS, Justice.

Gatewood A. Walden, proceeding pro se, appeals from a judgment

of the Montgomery Circuit Court dismissing his action against the 
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2

Disciplinary Board of the Alabama State Bar ("the Disciplinary Board").

We affirm. 

I. Facts and Procedural History

 Walden was admitted to the Alabama State Bar in 1966. In June 

2012, the Disciplinary Board found Walden guilty of charges brought 

against him and issued an order disbarring him from the practice of law 

in this State. This Court affirmed the order entered by the Disciplinary 

Board, without an opinion. See Walden v. Alabama State Bar Ass'n, (No. 

1111313, Dec. 14, 2012) 156 So. 3d 999 (Ala. 2012) (table). This Court 

subsequently overruled Walden's application for a rehearing, and the 

certificate of judgment issued on February 22, 2013. See Walden v. 

Alabama State Bar Ass'n, (No. 1111313, Feb. 22, 2013) 162 So. 3d 948 

(Ala. 2013) (table). After his disbarment, Walden initiated proceedings 

in both state and federal courts challenging the Disciplinary Board's 

findings related to his disbarment.1 Most recently, Walden commenced

1 See, e.g.: this Court's order of dismissal in Ex parte Walden (No. 

1120906, June 5, 2013) (dismissing petition to "withdraw the decision 

affirming the order of disbarment of Gatewood A. Walden"); this Court's 

order of dismissal in Ex parte Walden (No. 1130394, May 29, 2014) 

(dismissing both petition for a writ of mandamus directed to the Alabama 

State Bar Association and petition for reinstatement); the Montgomery 

Circuit Court's order of dismissal in Walden v. Alabama State Bar Ass'n 
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an action in the Montgomery Circuit Court requesting that the circuit 

court issue a writ of mandamus directing the Disciplinary Board to 

vacate its disbarment order on the basis that the order was void. Walden 

also claimed that, because the disbarment order was void, this Court's 

decision affirming that order was also void. The Disciplinary Board filed 

a motion to dismiss Walden's action, arguing, in relevant part, that the 

circuit court lacked subject-matter jurisdiction over the matter. The 

circuit court entered a judgment, dismissing the action. Walden filed a 

et al. (No. CV-18-9000378, Sept. 17, 2018) (dismissing an action against 

the Alabama State Bar Association and certain Bar officials for lack of 

jurisdiction), aff'd, Walden v. Alabama State Bar Ass'n, 320 So. 3d 545 

(Ala. 2020); the Montgomery Circuit Court's order of dismissal in Walden 

v. Alabama State Bar Ass'n et al. (No. CV-21-900727, Aug. 4, 2021) 

(dismissing action against the Alabama State Bar Association and other 

defendant for lack of jurisdiction and further ordering that Walden was 

"barred from filing any future pleading, petition or complaint premised 

on his disbarment"); the Lowndes Circuit Court's order of dismissal in 

Walden v. Disciplinary Bd. of Alabama State Bar (No. CV-22-000007, 

Sept. 7, 2022) (dismissing petition for writ of mandamus directed to the 

Disciplinary Board); and the Montgomery Circuit Court's order of 

dismissal in Walden v. Disciplinary Bd. of Alabama State Bar (No. CV23-000070, May 8, 2023) (dismissing action against the Disciplinary 

Board). Walden also filed a "Petition for Reinstatement" in the United 

States District Court for the Middle District of Alabama. That 

proceeding culminated in Walden's disbarment from the practice of law 

in that court. See In re Walden, 709 F. App'x 644 (11th Cir. 2017).
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motion to alter, amend, or vacate the judgment, which was denied. This 

appeal followed. 

II. Standard of Review

This Court reviews de novo the issue whether the circuit court

lacked jurisdiction in this case. State Dep't of Revenue v. Arnold, 909 So. 

2d 192 (Ala. 2005). 

III. Discussion

A. Merits

Walden argues, without citation to any legal authority, that the 

circuit court erred in dismissing his action against the Disciplinary Board 

because, he says, "[u]nder Alabama law, the Montgomery Circuit Court 

has supervisory jurisdiction over the Disciplinary Board of the State 

Bar." Walden's brief at 10 (emphasis in original). However, Walden

entirely ignores this Court's holding in Walden v. Alabama State Bar 

Ass'n, 320 So. 3d 545 (Ala. 2020). In that case, Walden challenged a 

judgment of the Montgomery Circuit Court dismissing his action against, 

among others, the Disciplinary Board. In his complaint, Walden had 

requested, in relevant part, that the circuit court enter a judgment (1) 

declaring that the revocation of his law license was void and (2) directing 
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the Alabama State Bar reinstate him as a member of the Bar in good 

standing. The circuit court entered a judgment dismissing the action, 

explaining that the court did not "'have the jurisdiction to review nor the 

ability to grant the relief [Walden] is requesting.'" 320 So. 3d at 548. In 

affirming that judgment, this Court made it abundantly clear that the

circuit courts of this State have no jurisdiction over orders entered in Bar 

disciplinary proceedings: 

"The trial court correctly concluded that it did not have 

the power to grant Walden the relief he seeks. As detailed 

above, while Walden's disciplinary proceeding was pending in 

2011, he initiated an action in the Montgomery Circuit Court 

asking the court to insert itself into the disciplinary 

proceeding and to dissolve his interim suspension. The trial 

court declined to do so and dismissed his action, explaining to 

Walden in a reasoned order that matters involving the 

discipline of members of the State Bar were within the 

exclusive jurisdiction of the State Bar 'with review by the 

Supreme Court of Alabama.' Rule 1(a)(1), Ala. R. Disc. P. This 

governing principle has not changed since then; to the 

contrary, it has only been reinforced. See, e.g., Nichols v. 

Alabama State Bar, 815 F.3d 726, 732 (11th Cir. 2016) 

(recognizing that 'Alabama law delegates to the State Bar, 

with supervision by the Supreme Court of Alabama, the power 

to investigate and discipline attorney misconduct').

"Simply put, circuit courts in this State have no 

authority to reverse a judgment made by the State Bar in a 

disciplinary proceeding, to admit an attorney to the State Bar, 

or to direct the State Bar to reinstate an attorney who has 

previously been disbarred. A party like Walden who is 

aggrieved by an adverse decision of the State Bar has the 
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right under Rule 12(f), Ala. R. Disc. P., to seek appellate 

review of that decision -- from this Court -- not from a circuit 

court. Walden, in fact, availed himself of Rule 12(f) when he 

appealed his order of disbarment to this Court, which 

affirmed the State Bar's decision. The trial court has no 

jurisdiction to review that order of disbarment again, and it 

therefore properly dismissed Walden's complaint to the extent 

that complaint sought declaratory and injunctive relief 

regarding the status of his membership in the State Bar."

Id. at 548. (some emphasis added).

Our holding in Walden, 320 So. 3d 545, was, and is, distinct, precise, 

and unambiguous, providing no possibility that a circuit court could ever 

have jurisdiction to entertain an action seeking a writ of mandamus 

directing the Disciplinary Board to vacate an order disbarring an 

attorney from the practice of law. Accordingly, the circuit court in this 

case did not err in dismissing Walden's action. "'Lacking subject-matter 

jurisdiction [a court] may take no action other than to exercise its power 

to dismiss the action. ... Any other action ... is null and void.'" State v. 

Property at 2018 Rainbow Drive, 740 So. 2d 1025, 1029 (Ala. 1999) 

(quoting Beach v. Director of Revenue, 934 S.W.2d 315, 318 (Mo. Ct. App. 

1996)). 

B. Sanctions
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Despite the finality of the order disbarring Walden from the 

practice of law, this Court's holding in Walden, 320 So. 3d 545, and the 

holding of this opinion, this Court has little doubt that Walden will 

continue to file unwarranted challenges to his disbarment, thus abusing 

this Court's limited resources.2 We therefore conclude that a sanction is 

merited. This Court has the inherent power to protect against repetitious 

and frivolous filings that result in an abuse of the judicial process. As 

the United States Supreme Court has noted, "[e]very paper filed with the 

Clerk of this Court, no matter how repetitious or frivolous, requires some 

portion of the institution's limited resources. A part of the Court's 

responsibility is to see that these resources are allocated in a way that 

promotes the interests of justice." In re McDonald, 489 U.S. 180, 184 

(1989). See also Peterson v. State, 817 So. 2d 838, 840 (Fla. 2002) ("This 

Court has a responsibility to ensure every citizen's right of access to the 

courts. ... A limitation on [the petitioner's] ability to file would further 

the constitutional right to access for other litigants because it would 

permit this Court to devote its finite resources to the consideration of 

2At this juncture, Walden's sole recourse is to seek reinstatement 

pursuant to Rule 28 of the Alabama Rules of Disciplinary Procedure. 
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legitimate claims filed by others."). In order to promote the interests of 

justice, Walden is precluded from proceeding pro se in this Court in any 

matters relating to his disbarment; any future filings in this Court 

challenging Walden's disbarment must be signed by a member in good 

standing of the Alabama State Bar. Under the sanction imposed, Walden 

is not being completely denied access to this Court. Rather, he may have 

access to the Court through the assistance of counsel, if such counsel 

determines that a proceeding relating to Walden's disbarment may have 

merit and can be pursued in good faith. 

IV. Conclusion

We affirm the judgment of the circuit court dismissing Walden's 

action for lack of subject-matter jurisdiction. The Clerk of this Court is 

hereby instructed to reject future filings that in any way relate to 

Walden's disbarment, unless signed by a member in good standing of the 

Alabama State Bar. 

AFFIRMED.

Parker, C.J., and Wise, Stewart, and Cook, JJ., concur.