Justia Alabama Supreme Court Opinion Summaries

In 2008, James Ware was convicted of first-degree rape, first-degree burglary, and first-degree robbery, for which he was sentenced as an habitual felony offender to three sentences of life imprisonment, to be served consecutively. Ware appealed his convictions to the Court of Criminal Appeals. The Court of Criminal Appeals affirmed. On appeal to the Court of Criminal Appeals, Ware argued: (1) the trial court violated his Sixth Amendment right to confront the witnesses against him when it admitted a DNA-profile report that was based on the work of laboratory technicians who did not testify at trial; and (2) the trial court erred in denying his motion for a judgment of acquittal on the robbery and burglary charges because there was not sufficient evidence to prove beyond a reasonable doubt that he was armed with a deadly weapon or a dangerous instrument. The Supreme Court affirmed as to the first issue and reversed as to the second. View "Ware v. Alabama " on Justia Law

In consolidated appeals, defendants the Alabama Department of Corrections, various department officials, and Governor Robert Bentley, appealed in case no. 1111588, the trial court's determination limiting certain deductions from work-release earnings for inmates. In case no. 1120264, Jerry Mack Merritt (as sole representative of the plaintiff class) cross-appealed, raising numerous challenges to the trial court's final judgment. After its review, the Supreme Court dismissed the appeal in case no. 1120264 as untimely filed; in case no. 1111588, the Court reversed and remanded. The Court found that the department's interpretation of section 14-8-6 as permitting its collection of charges, which were not incident to the inmate's confinement, in excess of a 40% withholding cap established by that statute was both reasonable and consistent with the statutory language. View "Thomas v. Merritt" on Justia Law

The Supreme Court concluded the Court of Criminal Appeals erred when it affirmed Derek Baker's conviction for trafficking in marijuana. Baker was entitled to production of the seized substance in his case for the purpose of having it independently tested. The denial of the motion for production resulted in prejudice to Baker and violated his right to due process. Additionally, because the record did not indicate that Baker ever requested funds for an expert to conduct the independent testing, he was not required to demonstrate that there was a particularized need for such testing. Accordingly, the trial court exceeded its discretion when it denied Baker's motions seeking independent testing and evaluation of the substance purported to be marijuana. The Court reversed the appellate court and remanded the case for further proceedings. View "Baker v. Alabama" on Justia Law

The State petitioned the Supreme Court for review of a Court of Criminal Appeals' decision to reverse Curtis Maurice Sanders's conviction for third-degree burglary. Sanders entered a guilty plea. As a matter of first impression, the issue in this case before the Court was whether an unoccupied house that was scheduled for demolition constituted a "building" as defined in 13A-7-1(2), Ala. Code 1975, for purposes of 13A-7-7(a), Ala. Code 1975. "If the legislature had intended to exclude an abandoned building awaiting demolition from the purview of the statute, it could have included express language to that effect in the statute. However, it did not do so, and this Court will not read such language into the statute." Accordingly, the Court reversed the Court of Criminal Appeals' judgment and remanded the case for further proceedings. View "Sanders v. Alabama" on Justia Law

In petitions for a writ of mandamus, two juvenile offenders sought dismissal of capital-murder indictments based on "Roper v. Simmons," (543 U.S. 551 (2005)), and "Miller v. Alabama," (132 S.Ct. 2455 (2012)). Both juveniles argued that Alabama's capital-murder statute was unconstitutional as applied to them because the mandatory sentencing structure provides that all defendants charged with a capital offense, including juveniles, must receive either a sentence of death or a mandatory sentence of life imprisonment without parole. Upon review, the Supreme Court concluded the juveniles failed to show that the holding in Miller required it to dismiss the capital-murder indictments against them. Accordingly, their petitions for a writ of mandamus were denied. View "Alabama vs. Henderson " on Justia Law

The State sought certiorari for review of a decision of the Court of Criminal Appeals that reversed the Juvenile Court's decision to deny G.M.'s motion to suppress evidence that G.M. argued was obtained pursuant to an illegal search. The matter was one of first impression for the Supreme Court: whether evidence of a public-school student's association with an individual known to be involved in criminal activity and suspected of being affiliated with a gang, without more, constituted reasonable grounds for a search of the student by a school official under the Fourth Amendment. The Supreme Court concluded that it did not. Therefore, the Court affirmed the Court of Criminal Appeals' judgment. View "G. M. v. Alabama " on Justia Law

Joseph Lester Pate petitioned the Supreme Court Court for a writ of certiorari to review the Court of Criminal Appeals' affirmance by unpublished memorandum of the circuit court's denial of his motion for reconsideration of his sentence imposed pursuant the Habitual Felony Offender Act ("the HFOA"). The trial court dismissed Pate's "Kirby" motion because it erroneously believed that it lacked jurisdiction to consider it. The Court of Criminal Appeals, on remand from the Supreme Court's decision in "Ex parte Pate," affirmed the trial court's order because it determined that Pate was not entitled to review (on the merits) of a second "Kirby" motion because, it said, there was no indication that Pate's first "Kirby" motion had not properly been considered. The Supreme Court concluded that there was indeed no indication in the record that Pate's first "Kirby" motion was considered on the merits. The judgment of the Court of Criminal Appeals was reversed and the case remanded for further proceedings. View "Pate v. Alabama" on Justia Law

Defendant Reginald Tyrone Lightfoot challenged his conviction for trafficking in cocaine and his sentence of 15 years' imprisonment. The Supreme Court granted certiorari review to determine, as a matter of first impression, whether an Apprendi error in applying a sentence enhancement was automatically harmless when the erroneous application of the enhancement did not increase the sentence beyond the statutory maximum for the underlying offense. The Court held that it was not, and reversed the Court of Criminal Appeals. View "Lightfoot v. Alabama " on Justia Law

The Supreme Court held that Defendant's Rule 32 petition should not have been dismissed on the grounds that his claim for relief under Rule 32.1 lacked allegations to negate the preclusive bars of Rule 32.1(a)(3) and (5). Defendant was convicted of capital murder and sentenced to death. He filed a Rule 32 petition for post-conviction relief, alleging in part that the State failed to disclose exculpatory evidence. The State asserted in response that defendant's claims were procedurally barred by Rule 32.2(a)(3) and (5) because defendant could have, but did not, raise the issue at trial. The trial court dismissed defendant's application and the Court of Criminal Appeals affirmed. The case was remanded for further proceedings. View "Beckworth v. Alabama" on Justia Law

Luther Pate, IV sought review of the Court of Criminal Appeals' decision to affirm his conviction for menacing. In a matter of first impression, the issues before the Supreme Court were: (1) whether lawfully arming oneself was a "physical action" as defined in the state menacing statute; and (2) whether defense-of-premises was applicable in this case. Finding that the Court of Criminal Appeals erred in its analysis of the menacing statute, the Supreme Court reversed and remanded the case for further proceedings. The Court held that its reversal on the menacing issue pretermitted discussion of the defense-of-premises issue. View "Pate IV v. City of Tuscaloosa" on Justia Law