Ex parte State of Alabama.

The Alabama Supreme Court granted certiorari review to address a question of first impression: whether it was improper to admit into evidence in a trial de novo in the circuit court, evidence of a defendant's guilty plea made in the district court. Otha Lee Woods pleaded guilty to and was convicted of driving under the influence of alcohol. The Court of Criminal Appeals reversed the circuit court's judgment, holding that the circuit court's admission of evidence of Woods's plea of guilty made in the district court "violate[d] well settled principles of law regarding a trial de novo and that the admission of such evidence [was] inherently prejudicial." The Supreme Court disagreed. “A trial de novo in the circuit court provides a defendant with a clean slate with regard to a determination of whether he or she is guilty of the offense charged. It is an opportunity to have the defendant's guilt or innocence determined without consideration of the outcome, i.e., the judgment, of the earlier proceeding. Therefore, because the judgment from the prior court proceeding, and not the defendant's guilty plea, answers the ultimate question posed in the trial de novo – whether the defendant is guilty of the offense charged - admission of the judgment, but not of the guilty plea, is prohibited at the trial de novo.” View "Ex parte State of Alabama." on Justia Law