Justia Alabama Supreme Court Opinion Summaries

Larry Dunaway filed a Rule 32, Ala. R. Crim. P. petition challenging his 1997 convictions for the capital murder of his girlfriend Tressa Patterson and her 22-month-old son James. The Rule 32 court entered an order denying Dunaway's petition, and the Court of Criminal Appeals affirmed. Dunaway petitioned for a writ of certiorari to review the Court of Criminal Appeals' decision in "Dunaway II." The Court granted the writ to consider: (1) Dunaway's claims of misconduct by four jurors who allegedly failed to disclose pertinent information during voir dire; (2) Dunaway's claim that the Rule 32 court erred by denying his "Brady v. Maryland" (373 U.S. 83 (1963)) claims that he was denied due process as a result of the District Attorney's failure to disclose alleged relationships between him and certain jurors; and (3) Dunaway's claim that he received ineffective assistance of trial counsel during the sentencing phase of his trial. Because the Supreme Court concluded that Dunaway was entitled to a new trial based on his juror-misconduct claim, the Court declined to address the nondisclosure claim as to the DA and the ineffective-assistance-of-counsel claim. View "Dunaway v. Alabama " on Justia Law

Sarah Hicks petitioned the Supreme Court for review of the Court of Criminal Appeals' judgment affirming her conviction, following a guilty plea, for chemical endangerment of a child for exposing her unborn child to a controlled substance. In affirming the judgment of the Court of Criminal Appeals, the Supreme Court held that use of the word "child" in the chemical-endangerment statute included all children, born and unborn, and furthered Alabama's policy of protecting life from the earliest stages of development. View "Hicks v. Alabama " on Justia Law

Jennifer Leigh Clayton and Justin Andrew Bailey filed separate motions requesting that the trial court suppress evidence seized in a warrantless search of their apartment by law-enforcement officers in early 2011. A grand jury issued an indictment charging Clayton and Bailey with first-degree unlawful manufacturing of methamphetamine. After a hearing, the trial court granted their motions to suppress the evidence. The State appealed, and the Court of Criminal Appeals affirmed the trial court's order as to the search. The State appealed that decision. The Supreme Court did "not find persuasive Clayton and Bailey's argument that the behavior of the officers indicated that there was no need for immediate action. A fair reading of the record establishes that, in light of the odor the law enforcement officers recognized to be consistent with the process of manufacturing methamphetamine, the law-enforcement officers were concerned about their safety and the safety of the occupants of the apartment and the public." Because law-enforcement had probable cause to believe that methamphetamine was being manufactured inside the apartment and because the process of manufacturing methamphetamine, in light of its explosive nature, created an exigent circumstance, the law-enforcement officers' warrantless entry into and search of Bailey and Clayton's apartment was proper. Therefore, the judgment of the Court of Criminal Appeals holding otherwise was reversed, and this case was remanded to that court for further proceedings. View "Alabama v. Clayton " on Justia Law

The Alabama Supreme Court focused on two appeals (case no. 1101384 and case no. 1110310) and two petitions for writs of mandamus (case no. 1101313 and case no. 1110158) filed by the State of Alabama, all challenging orders entered by a circuit judge in Greene County requiring State officials to return to items seized by the State as contraband pursuant to search warrants previously issued by the Greene Court. In addition, the Supreme Court reviewed a petition for a writ of mandamus (case no. 1130598) filed by the State seeking relief from the refusal of a district judge in Greene County to issue warrants similar to the warrants involved in the first four cases based on evidentiary submissions similar to those provided by the State in those same four cases. The latter case involved the same potential defendants and gaming establishments as the first four cases, as well as similar gambling devices alleged by the State to be illegal. Moreover, the district judge in case no. 1130598 relied upon the judgment of the trial judge in the former cases in refusing to issue the warrants in that case. Upon review of the trial record of all parties' cases involved, the Supreme Court concluded that the circuit court was asked to preemptively adjudicate (within the confines of a motion filed under Rule 3.13, Ala. R. Crim. P.) the lawfulness of property seized as contraband. The Court concluded the Circuit Court had no jurisdiction to do so. Therefore the Supreme Court vacated the orders of the trial court in case no. 1101384 and 1110310 and dismissed those actions. The Court dismissed the appeals in those cases, and the related petitions for writ of mandamus then pending in case no. 1101313 and case no. 1110158. As to case no. 1130598, the Court, by separate order, granted the State's petition for a writ of mandamus and remanded this case for the immediate issuance of the warrants for which the State applied. View "Alabama v. Greenetrack, Inc. " on Justia Law

The Supreme Court granted certiorari to review the Court of Criminal Appeals' decision that it did not have jurisdiction to entertain Earnest Walker's appeal from the new sentence imposed for his 2006 guilty-plea conviction for second-degree receiving stolen property. The new sentence was imposed after it was determined, following Walker's filing a Rule 32, Ala. R. Crim. P., petition, that Walker's original sentence exceeded the maximum authorized by law. The Court of Criminal Appeals dismissed Walker's appeal. The Supreme Court reversed and remanded, finding the trial court's exercise of discretion created a significant difference between the facts in the controlling case law and those in this case. "[D]ue process mandates that Walker have an opportunity to appeal his new sentence." View "Walker v. Alabama " on Justia Law

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