Justia Alabama Supreme Court Opinion Summaries

A woman called 911 to request a welfare check on her elderly neighbors’ home after noticing an unfamiliar vehicle and a young Black male there while the neighbors were out of town. When Officer Smith of the Childersburg Police Department arrived, he found a man watering flowers and asked if he lived at the house. The man, who identified himself as Pastor Jennings and said he lived across the street, explained he was watching the house for the neighbors. When asked for identification, Jennings became agitated and refused to provide any. Other officers arrived, and after Jennings repeatedly refused to further identify himself, he was arrested and charged with obstructing a governmental function.After the charge was dismissed, Jennings sued the officers and the City of Childersburg in the United States District Court for the Northern District of Alabama, alleging unlawful and retaliatory arrest under federal law and false arrest under state law. The district court granted summary judgment and dismissal in favor of the officers and the City, finding that Jennings violated Alabama’s stop-and-identify statute, Ala. Code § 15-5-30, by refusing to give his complete name. The United States Court of Appeals for the Eleventh Circuit reversed, relying on a prior interpretation of the statute that prohibited officers from demanding physical identification. On remand, the district court found the law’s interpretation uncertain and certified a question to the Supreme Court of Alabama.The Supreme Court of Alabama held that Ala. Code § 15-5-30 does not prohibit law enforcement officers, during a valid Terry stop, from requesting physical identification if a suspect gives an incomplete or unsatisfactory oral response regarding their name and address. The court clarified that suspects must provide sufficient identifying information and that failure to do so can constitute a violation of Alabama law. View "Jennings v. Smith" on Justia Law

A married couple who had served as foster parents were indicted for capital murder in connection with the death of an infant, E.E., who had been placed in their care by the Marshall County Department of Human Resources due to his medical needs and his parents’ inability to care for him. The child, who required a feeding tube and frequent hospitalization, died while in their custody. In July 2024, a Blount County grand jury indicted both individuals for capital murder, and they were denied bail by the Blount Circuit Court after evidentiary hearings.The petitioners each moved for bail, arguing that the State had the burden to present evidence sufficient to show they were not entitled to bail. The State countered that, in capital cases, the indictment itself creates a presumption of guilt for purposes of bail, and the burden shifts to the defendants to overcome this presumption. The Blount Circuit Court agreed with the State, denied bail, and found that the evidence did not overcome the presumption arising from the indictment. The Court of Criminal Appeals subsequently denied habeas petitions challenging the denial of bail.Upon review, the Supreme Court of Alabama reaffirmed the longstanding “presumption rule,” which holds that, in capital cases, an indictment creates a presumption of guilt for purposes of bail, and the defendant must overcome this presumption by presenting sufficient evidence. The Court declined to overturn this rule, citing stare decisis and legislative acquiescence, especially in light of recent constitutional and statutory amendments. The Court held that the trial court did not err in denying bail because the petitioners had not overcome the presumption of guilt, and it denied both petitions for writs of habeas corpus. View "State of Alabama v. Grimes" on Justia Law

A woman alleged that her boyfriend assaulted her during their relationship and filed a petition for protection from abuse (PFA) in Madison Circuit Court. Judge Linda F. Coats, serving as a special circuit-court judge, granted an ex parte protection order and scheduled a hearing. Subsequently, the boyfriend was charged criminally with domestic violence arising from the same incident. At the PFA hearing, Judge Coats held a pretrial immunity hearing under Alabama’s stand-your-ground statute, determined the boyfriend acted in self-defense, and denied the PFA petition, stating he was immune from criminal and civil prosecution.In the criminal case, Judge Patricia D. Demos dismissed the charge against the boyfriend, relying on Judge Coats’s immunity determination from the PFA case. The State, through the Madison County District Attorney’s Office, petitioned the Madison Circuit Court for a writ of mandamus, arguing Judge Coats lacked authority to grant immunity in the PFA proceeding without notice to the State and that Judge Demos erroneously dismissed the criminal charge based on the PFA order. The Madison Circuit Court (Judge Donna S. Pate) granted the writ, ordering Judge Coats to vacate the immunity portion of her PFA order and Judge Demos to reinstate the criminal case.The Supreme Court of Alabama reviewed appeals by Judge Coats and the boyfriend. The Court held that Judge Coats lacked standing to appeal and that the portion of the circuit court’s mandamus order directed to Judge Coats was void, as Judge Pate did not have supervisory jurisdiction over a special circuit-court judge. The Court dismissed Judge Coats’s appeal and the corresponding part of the boyfriend’s appeal. The remaining portion of the boyfriend’s appeal, which concerned the mandamus to Judge Demos in the criminal case, was transferred to the Court of Criminal Appeals, as it fell under its appellate jurisdiction. View "Coats v. State of Alabama" on Justia Law

A 45-year-old man was convicted in Greene Circuit Court of first-degree rape of his 16-year-old niece, following an alleged incident at his fish-camp trailer. The prosecution presented no physical evidence, instead relying primarily on the niece’s testimony and that of other witnesses to whom she had spoken after the event. A key witness for the State was a supervisor from the Department of Human Resources (DHR), who investigated the allegations but did not interview the defendant. During trial, the DHR supervisor testified that, after her investigation, she found the allegations to be "indicated," meaning DHR found enough evidence to support them. The defendant objected to this testimony, arguing it inappropriately addressed the ultimate issue of guilt, but the trial court overruled the objection.After the jury convicted the defendant and he was sentenced, he moved for a judgment of acquittal or a new trial, raising the issue of the DHR supervisor’s testimony. The trial court denied the motion. The Alabama Court of Criminal Appeals affirmed the conviction, rejecting the argument that admission of the lay-witness testimony about the ultimate issue was improper.The Supreme Court of Alabama reviewed whether the Court of Criminal Appeals had erred in allowing lay-witness testimony that embraced the ultimate issue of guilt, in light of the precedent established in Naylor v. State, 108 So. 3d 1063 (Ala. Crim. App. 2012). The Supreme Court held that the trial court erred by admitting the DHR supervisor's lay opinion on the ultimate issue, that this error was preserved by objection, and that it was not harmless given the centrality of witness credibility and lack of physical evidence. The Supreme Court reversed the decision of the Court of Criminal Appeals and remanded the case for further proceedings. View "Ex parte Randolph" on Justia Law

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