Justia Alabama Supreme Court Opinion Summaries

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Pate petitioned the Supreme Court Court for a writ of certiorari to review the Court of Criminal Appeals' affirmance by unpublished memorandum of the circuit court's denial of his motion for reconsideration of his sentence imposed pursuant the Habitual Felony Offender Act ("the HFOA").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

Petitioner Tonya Cate sought a writ of mandamus to direct the trial court to vacate its order requiring her to submit for a mental examination. She was indicted for capital murder and did not use the not-guilty-by-reason-of-mental-defect defense. At the onset, a mitigation expert was concerned Petitioner had not been subjected to the exam to determine her competency to stand trial. Petitioner's attorney filed a motion for a continuance for his client to be examined, but did not specify that the exam was only to determine competence. The State filed a motion to have Petitioner examined for both current mental condition and competency to stand trial. Petitioner claims to have not been served with a copy of the trial court's order that granted the State's motion, and objected. In her motion to avoid the exam, Petitioner asked in the alternative that if the exam took place, her attorney be present to advise her of her constitutional rights. Before the court ruled on the motion, Petitioner withdrew her original motion, citing the mitigation expert's concerns had been allayed. The court entered its order requiring Petitioner to submit to the examination for then-current mental state and at the time of the alleged crime. Petitioner argued that after withdrawing her own motion for an examination, she could not be compelled to submit for examination. Because Petitioner did not use the mental-defect defense, the Supreme Court concluded that she could not be compelled to submit to the examination. Accordingly the Court granted the petition and issued the writ. View "Cate v. Alabama " on Justia Law

Roosevelt Upshaw appealed a circuit court's decision to deny his petition for habeas relief. In his petition, Upshaw alleged that the Alabama Department of Corrections ("ADOC") had erred in calculating the term of his sentence after he was arrested while on parole in that ADOC unlawfully denied him credit under 15-22-32(a), Ala. Code 1975, for the time he was incarcerated in Georgia. Finding no error, the Supreme Court affirmed. View "Upshaw v. Alabama" on Justia Law

Jermaine Parker was convicted of conspiracy to commit a controlled-substance crime (the unlawful distribution of cocaine), and of obstructing governmental operations. The Supreme Court granted certiorari review to consider whether the decision of the Alabama Court of Criminal Appeals, which affirmed the convictions in an unpublished memorandum, conflicted with "Ex parte Williams," (468 So. 2d 99, 101 (Ala. 1985)) regarding the sufficiency of the evidence to support Parker's conviction for conspiracy to commit a controlled-substance crime. The Court denied certiorari review with regard to Parker's conviction for obstructing governmental operations. After review of the trial court record and the unpublished appellate court opinion, the Supreme Court concluded that the evidence presented in this matter "speculative" in nature: "Such proof is always insufficient, unless it excludes, to a moral certainty, every other reasonable hypothesis, but that of the guilt of the accused. No matter how strong the circumstances, if they can be reconciled with the theory that some other person may have done the act, then the defendant is not shown to be guilty, by that full measure of proof which the law requires...." The Court reversed the appellate court and remanded the case for further proceedings. View "Ex parte Parker" on Justia Law

Derrick Ervin appealed a summary judgment in favor of the City of Birmingham seeking the return of $178,858. The money was taken pursuant to a search of a vehicle impounded by police in connection with suspected drug activity. During the search, officers found a black bag containing thirty-two bundles of cash, and a shoe box in the back seat containing six more bundles in U.S. currency. Officers also found assorted documents bearing Ervin's name inside the passenger compartment. Ervin did not contest those facts in federal district court. In this action, however, Ervin contended that the cash was initially seized by the Birmingham Police Department (BPD), not by the Drug Enforcement Agency (DEA), and that the cash was subsequently transferred by "unknown Birmingham police officers ... to the DEA to commence forfeiture or condemnation proceedings" in the federal court. The federal district court entered a final judgment forfeiting the $178,858 to the United States. Ervin did not appeal that judgment and did not seek any postjudgment relief from it in the federal court itself. Pursuant to "equitable sharing" of the seizure, the City received the majority of the cash for its role in the operation, and the DEA kept a small percentage. Ervin alleged that, because such forfeiture proceedings had never been instituted, he was entitled to the return of the subject property. "Even if all these contentions were correct, they amount only to an attack on the authority of the federal district court to exercise jurisdiction over the res in an in rem action, not an attack on the subject-matter jurisdiction of the federal court over a forfeiture action brought under federal law. As such, they come too late and are being advanced in the wrong court." The Alabama Supreme Court affirmed the forfeiture. View "Ervin v. City of Birmingham " on Justia Law

The State through the Alabama Attorney General, sought a writ of mandamus to direct the presiding judge of the Macon Circuit Court to issue a search warrant as to "certain allegedly illegal gambling devices and related items" at a facility known as "Quincy's 777 Casino at Victoryland" in Shorter. The Supreme Court granted the State's petition and issued the writ under seal until the execution of the warrant. The execution having been accomplished, the Supreme Court removed the seal from this matter and in this opinion, addressed the reasons for issuing the writ. Upon careful consideration of the case law and statutes pertaining to this matter, the Supreme Court expounded on eight points of contention it had with the circuit court for denying the warrant. The Court concluded that the circuit court exceeded its discretion in denying the warrant, and as such, the State was entitled to an order directing the court to grant the warrant application. View "Ex parte State of Alabama (In re: Sealed Case)" on Justia Law