Lynch v. State
In Lynch v. State, 587 So. 2d 306, 307 (Ala. 1991), the Alabama Supreme Court remanded a conviction of second-degree robbery to the Court of Criminal Appeals. The Court of Criminal Appeals then reversed the conviction and remanded for new trial based on a different issue.
The Supreme Court found the Court of Appeals' reversal went beyond the mandate of the remand order.
The Supreme Court held the trial court's duty is to comply with the appellate mandate, carrying out its intent and meaning as determined by the directions of the reviewing court.
On remand, a lower court is not free to address issues other than those identified in the remand order. 587 So. 2d at 307-08.