Justia Alabama Supreme Court Opinion Summaries

Several individuals were convicted in separate proceedings in the Huntsville Municipal Court for violating city ordinances. Each person appealed his conviction to the Madison Circuit Court, seeking a trial de novo. Before those trials occurred, each defendant moved to dismiss the complaint, arguing that the municipal-court complaints failed to properly allege that the ordinances had been duly adopted and, in some cases, that the complaints referenced non-existent sections of the Alabama Code. All of these arguments were raised for the first time in the circuit court.The Madison Circuit Court granted the motions to dismiss in each case, sometimes stating that the complaints failed to confer jurisdiction. The City of Huntsville appealed these dismissals to the Alabama Court of Criminal Appeals, which consolidated the cases, reversed the circuit court’s judgments, and remanded for further proceedings. The defendants then sought review by the Supreme Court of Alabama, which consolidated the cases for decision.The Supreme Court of Alabama held that any defects in the municipal-court complaints did not deprive the circuit court of subject-matter jurisdiction, as that jurisdiction is conferred by statute. The Court further held that the defendants did not waive their challenges to the sufficiency of the complaints by failing to raise them in municipal court; such challenges could be raised during the pendency of the proceedings, including in the circuit court. However, the Court concluded that the municipal-court complaints met the requirements of the Alabama Rules of Criminal Procedure, specifically Rule 13.2(a), and did not need to include formal averments about the adoption of the ordinances. The Court affirmed the judgments of the Court of Criminal Appeals. View "Ex parte Sandifer" on Justia Law

Law enforcement officers attempted to stop a vehicle driven by Jeremy S. Mitchem after observing suspicious behavior and an expired tag. Mitchem fled, leading to a high-speed chase that ended in a collision. Upon searching the vehicle, officers found various controlled substances and $6,646 in cash on Mitchem’s person. Mitchem admitted to selling drugs and described his pricing, but claimed the cash was from his father to buy a vehicle. He denied knowledge of the drugs in the car and provided an alternative explanation for his actions.The Madison Circuit Court held a trial where the State sought forfeiture of the cash under the former version of § 20-2-93, Ala. Code 1975, arguing it was proceeds from or intended for drug transactions. The trial court, after hearing testimony and considering the evidence, found in favor of the State, concluding that the State had established a prima facie case for forfeiture. Mitchem’s postjudgment motion, which included an unsworn statement from his father about the source of the funds, was denied. Mitchem appealed.The Alabama Court of Civil Appeals reversed the trial court’s judgment, holding that the decision was against the great weight of the evidence because there was no concrete evidence tying the cash to a specific drug transaction. The State then sought review.The Supreme Court of Alabama granted certiorari, reversed the Court of Civil Appeals, and remanded the case. The Supreme Court held that the State is not required to trace seized currency to a specific drug transaction to meet its burden under the former § 20-2-93. The trial court’s finding that the cash was subject to forfeiture was not contrary to the great weight of the evidence, given Mitchem’s admissions and the circumstances of the seizure. View "In re Mitchem v. State" on Justia Law

Corey Lee Walton was convicted of reckless manslaughter after allegedly shooting and killing Christopher Champion during a brawl at a party. The evidence at trial indicated that Walton and his friend were pursued and surrounded by a group intending to harm them. Walton pulled a gun and, while being tackled, allegedly fired it, resulting in Champion’s death. Walton’s defense argued both that the prosecution had not proven he was the shooter and, alternatively, that he acted in self-defense. Walton was also charged with second-degree assault for allegedly shooting his friend, but was acquitted of that charge.The case was first tried in the Tuscaloosa Circuit Court, where the State introduced evidence of Walton’s prior criminal convictions, including attempted murder and other offenses, which had led to a court order prohibiting him from possessing firearms. The trial court admitted this evidence, reasoning it was relevant to whether Walton was acting unlawfully and thus not entitled to a “stand your ground” defense. Walton’s counsel objected, arguing that only common-law self-defense was at issue, not stand-your-ground, and that the details of the prior convictions were highly prejudicial. The trial court instructed the jury that Walton had a duty to retreat and that the prior crimes were relevant only to his illegal possession of the firearm.The Alabama Court of Criminal Appeals affirmed the conviction, finding the admission of the prior crimes evidence permissible. On certiorari review, the Supreme Court of Alabama held that the trial court abused its discretion by admitting details of Walton’s prior crimes, as they were irrelevant and unduly prejudicial given the defense’s concession regarding unlawful firearm possession and the absence of a stand-your-ground claim. The Supreme Court reversed the judgment of the Court of Criminal Appeals and remanded the case for further proceedings. View "Walton v. State" on Justia Law

Briana Marquise Matthews, a former prison guard, was charged with two counts of custodial sexual misconduct for having sexual encounters with an inmate. She pleaded guilty to both counts and was sentenced to 10 years, with 18 months to be served in custody and the remainder on probation. Upon starting her probation, Matthews was informed she had to comply with the Alabama Sex Offender Registration and Community Notification Act (ASORCNA) requirements.Matthews filed a petition in the St. Clair Circuit Court seeking relief from the ASORCNA requirements, arguing that these were not part of her plea agreement. The State responded that her petition was incorrectly filed in the criminal action and should be a new civil action. Matthews withdrew her petition and filed a new one as a civil action, seeking relief from the ASORCNA requirements and restrictions. The circuit court temporarily relieved her from these requirements pending further orders but ultimately denied her petition, stating that her convictions were not among those listed in § 15-20A-24(a) for which relief could be sought.The Supreme Court of Alabama reviewed the case. It dismissed the appeal from the criminal action, stating that the circuit court lacked jurisdiction to consider the petition in the criminal case, making the order void. However, the court affirmed the judgment in the civil action, agreeing that Matthews's convictions for custodial sexual misconduct were not eligible for relief under § 15-20A-24(a). The court also noted that Matthews was not entitled to seek relief while still serving her probationary term. View "Matthews v. State of Alabama" on Justia Law

Joshua Lashawn Booth was convicted in 2018 of three counts of possession of obscene material and sentenced to 15 years in prison. While incarcerated, Booth filed an application for a writ of habeas corpus in the Bibb Circuit Court, claiming that the Alabama Department of Corrections (ADOC) refused to grant him correctional incentive time. Booth argued that the statute barring sex offenders from receiving such time did not apply to his convictions. ADOC moved to dismiss or for summary judgment, but the Bibb Circuit Court denied the motion and ruled in favor of Booth, ordering ADOC to calculate his correctional incentive time.ADOC appealed to the Court of Criminal Appeals, arguing that Booth's filing should have been a petition for a writ of certiorari in the Montgomery Circuit Court, not a habeas corpus application in the Bibb Circuit Court. The Court of Criminal Appeals agreed, reversed the Bibb Circuit Court's judgment, and directed the case to be transferred to the Montgomery Circuit Court.The Supreme Court of Alabama reviewed the case to determine if the Court of Criminal Appeals' decision conflicted with Ex parte Culbreth and Ex parte Tanksley. The Supreme Court concluded that the issue was one of venue, not jurisdiction, and that ADOC had waived its objection to improper venue by not raising it in the Bibb Circuit Court. The Supreme Court found that the Court of Criminal Appeals' decision was in conflict with the precedent that venue objections can be waived if not timely raised. Consequently, the Supreme Court reversed the Court of Criminal Appeals' decision and remanded the case for proceedings consistent with its opinion. View "In re Alabama Department of Corrections v. Booth" on Justia Law

During the COVID-19 pandemic, John Svensen wrote a check to Jeff Hester's company, Ginesis, for several thousand bottles of hand sanitizer. The check bounced, leading Ginesis to sue Svensen and his company, Marketpointe, for the owed money. After a series of legal proceedings, Hester pressed charges against Svensen for the bad check, resulting in Svensen's arrest. The Lauderdale Circuit Court later dismissed the criminal complaint due to the statute of limitations, and Svensen subsequently sued Hester for malicious prosecution.The Lauderdale Circuit Court initially entered a default judgment against Svensen and Marketpointe for failing to answer Ginesis's complaint. After Svensen successfully vacated the default judgment, the court set a bench trial. However, Svensen did not appear, leading to another default judgment against him. After Svensen provided an excuse, the court vacated the default judgment and reset the trial. Meanwhile, Hester, on the advice of his attorney, took the bounced check to the Lauderdale County Sheriff's Department, leading to Svensen's arrest.The Supreme Court of Alabama affirmed the circuit court's summary judgment in favor of Hester. The court found that Hester had probable cause to believe that Svensen had committed the crime of negotiating a worthless negotiable instrument, as it is a crime in Alabama to knowingly write someone a bad check. The court rejected Svensen's argument that Hester lacked probable cause because the one-year statute of limitations for misdemeanor offenses had expired. The court reasoned that the expiration of the limitations period does not affect whether the defendant actually committed the offense charged. View "Svensen v. Hester" on Justia Law

In November 2015, Raymond Shane Greene was convicted of rape, sodomy, and sexual abuse of a child under 12 years of age. The trial court sentenced Greene to life imprisonment for the rape conviction, 99 years' imprisonment for the sodomy conviction, and 10 years' imprisonment for the sexual-abuse conviction. Greene had initially been tried for these offenses in August 2015, but a mistrial was declared due to the State's inadvertent failure to provide defense counsel with certain evidence. Greene was retried in November 2015 and convicted.Following the mistrial, Greene filed a motion to dismiss the charges against him on the ground of double jeopardy stemming from alleged prosecutorial misconduct. The trial court presumably denied that motion, as Greene was retried and convicted. On July 7, 2023, Greene, acting pro se, commenced an action in the Mobile Circuit Court, arguing that his November 2015 criminal convictions were due to be set aside on double-jeopardy grounds. He accused Nicki E. Patterson, the assistant district attorney who had prosecuted him, of prosecutorial misconduct. The Mobile County District Attorney's Office, on behalf of Patterson, filed a motion to dismiss, which the circuit court granted.The Supreme Court of Alabama affirmed the circuit court's decision. The court held that Greene could not use a rule of civil procedure to collaterally attack a criminal judgment; rather, Rule 32, Ala. R. Crim. P., provides the exclusive remedy for challenging a final judgment of conviction. Because the circuit court lacked subject-matter jurisdiction to entertain Greene's civil action, it properly granted Patterson's motion to dismiss. View "Greene v. Patterson" on Justia Law

This case stemmed from a cold-case murder that took place in 1981. An armed robber broke into a gas station where Russell Douglas was working, shot him several times, robbed the station, and fled. Douglas's murderer eluded capture. Then, some 30 years later, forensic scientists retested DNA evidence found at the crime scene and turned up a match to the respondent here, Nathaniel Dennis, who was serving a 600-year sentence in Virginia for an unrelated crime. In 2011, an Alabama grand jury indicted Dennis for the murder of Douglas, and he was transferred to Alabama to stand trial. In 2019, after a series of pretrial delays, Dennis was convicted of murder made capital because it was committed during a burglary. Dennis appealed, arguing that the delay between his indictment and trial violated his right to a speedy trial. The Court of Criminal Appeals agreed, holding that the over-eight-year period between 2011 and 2019 required the trial court to "presume" that the delay prejudiced Dennis's liberty interests -- even though Dennis had not put forward any affirmative evidence of prejudice and likely could not have done so because he was already serving a 600-year sentence in Virginia. The Alabama Supreme Court concluded this was error: the speedy-trial inquiry turns on how much delay has been caused by the government, not the bare amount of time between the indictment and trial. In this case, the portion of the delay caused by government negligence fell well short of the amount needed to justify a presumption of prejudice. Absent that presumption, Dennis' speedy-trial claim failed. The Court reversed the appellate court's judgment and remanded for consideration of the other arguments Dennis raised in his appeal. View "In re: Dennis v. Alabama)" on Justia Law

In 2019, the Alabama Legislature passed -- and Governor Kay Ivey signed -- House Bill 380 ("H.B. 380"), which became Act No. 2019-393, Ala. Acts 2019. As enacted, H.B. 380 amended various Code provisions, including § 15-22-21(a), Ala. Code 1975, creating the position of director of the Alabama Bureau of Pardons and Paroles ("the Bureau"), and § 15-22-20(b), Ala. Code 1975, addressing the nomination and appointment processes for the members of the Alabama Board of Pardons and Paroles ("the Board"). After H.B. 380 was enacted, Governor Ivey appointed Leigh Gwathney as chair of the Board pursuant to the new procedures set forth in § 15-22-20(b). In November 2020, the three-member Board convened and held a parole-consideration hearing for Angela Turner, an inmate who was serving a life sentence for murder. Following a review of Turner's file, the Board unanimously denied Turner's parole request. Around that same time, Governor Ivey appointed Cam Ward as the new director of the Bureau. In response to the Board's denial of parole, Turner filed suit against Governor Ivey, Ward, Gwathney, and the other members of the Parole Board, in which she sought a judgment declaring that Governor Ivey's appointment of Ward and Gwathney to their respective positions pursuant to the changes created by H.B. 380 violated the Alabama Constitution of 1901. She also, on behalf of the State of Alabama, petitioned for writs of quo warranto pursuant to § 6-6-591, Ala. Code 1975, alleging that Ward and Gwathney unlawfully held their respective positions. Finally, she alleged a 42 U.S.C. § 1983 claim against all the defendants on the basis that she had been denied due process during her parole-consideration hearing. The circuit court dismissed Turner's claims with prejudice. Finding no reversible error in the circuit court's order, the Alabama Supreme Court affirmed. View "Turner and the State of Alabama ex rel. Angela Turner v. Ivey, et al." on Justia Law

Dalen Gaines sought monetary and equitable relief against Walker County law-enforcement officers for their role in what Gaines claimed was a delayed bond hearing. After Gaines failed to appear at the Walker Circuit Court to answer criminal charges, the court issued a warrant for his arrest. Three months later, Walker County Sheriff's Deputy Christopher Doeur executed the warrant and took Gaines into custody. Afterward, Deputy Doeur filed a certificate of execution, informing the Circuit Court that he had arrested Gaines and placed him in the County jail. After about a month, Gaines remained incarcerated and had not yet appeared in court. The trial court granted the law-enforcement officers' motion to dismiss Gaines complaint here, and Gaines asked the Alabama Supreme Court to overturn that decision. The Court declined to do so, and affirmed dismissal. View "Gaines v. Smith" on Justia Law