Justia Alabama Supreme Court Opinion Summaries

Mark Allen Jenkins was convicted in March 1991 of two counts of capital murder which was committed during the course of a robbery and during the course of a kidnapping. By a vote of 10-2, the jury recommended that Jenkins be sentenced to death. The trial court accepted the jury's recommendation and sentenced Jenkins to death. In early 2012, the Supreme Court granted Jenkins's petition for a writ of certiorari only as to the ground challenging the Court of Criminal Appeals' affirmance of the trial court's order dismissing Jenkins's Rule 32 petition on the bases that the trial court adopted verbatim the State's proposed order, and the Court held in abeyance the other grounds raised in Jenkins's petition pending resolution of this issue. The Court affirmed the Court of Criminal Appeals' judgment insofar as it upheld the trial court's adoption of the State's proposed order denying Jenkins's Rule 32 petition; as to the remaining grounds the Court denied the petition for a writ of certiorari. View "Jenkins v. Alabama " on Justia Law

While represented by counsel, Defendant Stanford Earl Pritchett pled guilty to murder. Defendant then filed a pro se motion to set aside his guilty plea, asserting ineffective assistance of trial counsel. The trial court denied Defendant's motion without conducting a hearing and without making a determination that he had validly waived his right to counsel with respect to the motion. The Court of Criminal Appeals affirmed the trial court's order denying Defendant's motion to withdraw his guilty plea. Defendant petitioned the Supreme Court for a writ of certiorari as to that decision, asserting that it conflicted with "Berry v. Alabama," (630 So. 2d 127, 129 (Ala. Crim. App. 1993)). The Court granted the petition, and reversed the decision of the Court of Criminal Appeals and remanded the case. View "Pritchett v. Alabama " on Justia Law

John Woodruff appealed a circuit court order dismissing his malicious-prosecution, false imprisonment, and tort-of-outrage claims against the City of Tuscaloosa ("the City") and several of its employees. On October 16, 2006, Woodruff went to the Tuscaloosa Police Department headquarters to resolve a warrant that had been sworn against him for harassing communications. After presenting himself, Woodruff was arrested and handcuffed by a Tuscaloosa police officer and told to wait until another officer could arrive to complete the booking process. While waiting in the public lobby of police headquarters, Woodruff became involved in a verbal altercation with an off-duty Tuscaloosa police officer, and he was subsequently charged by Officer Canterbury with disorderly conduct, another Class C misdemeanor. Woodruff was thereafter booked and transported to the county jail, where he was released on bond later that night. On October 19, 2006, Woodruff returned to the Tuscaloosa Police Department to file a written complaint regarding the events surrounding his arrest and booking on October 16. The Tuscaloosa Police Department ultimately determined that Woodruff's complaint was without merit. On November 15, 2006, Woodruff was convicted of disorderly conduct. He thereafter sought a trial de novo on the charge in Circuit Court; however, in December 2008, while the matter was still pending, Woodruff and the City apparently reached an agreement to nol-pros the charge if Woodruff would undergo counseling. On January 2, 2009, the disorderly conduct charge was formally dropped. On January 3, 2011, Woodruff filed the this action. Upon review, the Supreme Court concluded that it was "evident" that Woodruff did not state a claim upon which relief could be granted. The Court affirmed the circuit court in denying his claims. View "Woodruff v. City of Tuscaloosa" on Justia Law

This appeal arose from a circuit court's dismissal of Brandon Johnson's action against Gary Hetzel, warden of the Donaldson Correctional Facility; Sean Carlton, a correctional officer trainee at the facility; and correctional officers Dennis Johnson and Joe Binder. Johnson was serving a life sentence without the possibility of parole following a conviction for murder. He was seen fighting with another inmate and placed under "house arrest" pending a disciplinary hearing. Johnson argued that the defendants "deliberately plac[ed] him in 'house arrest' two cells from [another inmate with whom he had the fight], and [that] the defendants were responsible for the protection of both inmates, but instead opened the door to both cells at which time [Johnson] and [the other inmate] got into another fight," in which, Johnson argued, he was injured. Johnson filed an affidavit of substantial hardship, requesting that the initial docket fee for his case be waived. Defendants filed a motion to dismiss the complaint or, in the alternative, for a summary judgment. The circuit court granted the defendants' motion and dismissed Johnson's complaint. Johnson has appealed the circuit court's judgment of dismissal, arguing, in pertinent part, that the circuit court never had jurisdiction over his case because he did not pay the necessary filing fee and the circuit court never approved either of the affidavits of substantial hardship he had filed. Upon review, the Supreme Court concluded that the filing of a court-approved verified statement of substantial hardship was not met in this case. Therefore, the circuit court did not have jurisdiction to enter its judgment dismissing Johnson's complaint. The Court ruled the circuit court's judgment void. "[B]ecause a void judgment will not support an appeal," the Court vacated the trial court's judgment and dismissed the appeal. View "Johnson v. Hetzel" on Justia Law

Defendant Amy Bishop Anderson petitioned the Supreme Court for a writ of mandamus to direct the Madison Circuit Court to compel the Office of Indigent Defense Services and the Comptroller's Office within the Department of Finance to comply with the circuit court's orders and disburse interim payments of fees to her retained experts. Upon review, the Supreme Court denied the petition. Anderson was indicted on charges of capital murder and attempted murder after she shot several of her colleagues during a biology-department faculty meeting at the University of Alabama in Huntsville in 2010. Defendant's defense counsel served notice that they indended to argue that Defendant was not guilty by reason of mental disease or defect. The circuit court entered an order granting defense counsel's ex parte motion for extraordinary expenses. The circuit court authorized defense counsel to retain the services of a neuropsychiatrist who evaluated Defendant, and ordered the comptroller to make immediate payment to cover the expert's retainer. According to Defendant, the expert began working on the case with a reasonable expectation of being paid at a later date. No payment was made. The Supreme Court concluded that while the circuit court entered the orders directing interim payments for Defendant's experts, Defendant did not show that the circuit court refused to enforce those orders. Based on this, Defendant did not satisfy her burden that the circuit court refused to enforce its orders. View "Alabama v. Anderson" on Justia Law

Defendant Amy Bishop Anderson petitioned the Supreme Court for a writ of mandamus to direct the Madison Circuit Court to compel the Office of Indigent Services and the Comptroller's Office within the state Department of Finance to comply with the circuit court's orders and disburse interim payments of fees to her retained experts. Anderson was indicted on charges of capital murder and attempted murder after she shot several of her colleagues during a biology-department faculty meeting at the University of Alabama in Huntsville on February 2, 2010. Anderson's defense counsel served notice that they intended to argue that Anderson was not guilty by reason of mental disease or defect. The circuit court entered an order granting defense counsel's ex parte motion for extraordinary expenses, but no payment was made in response to the court's order. Finding that Anderson did not show that she satisfied her burden of showing a refusal by the circuit court to enforce its orders, the Supreme Court denied Anderson's petition for the writ of mandamus. View "Alabama v. Anderson" on Justia Law

Several Citites and their employees, police officers J.J. Oglesby, J.M. Stewart, A.T. Caffey, Q.O. Commander, and N.W. McMahon petitioned the Supreme Court for a writ of mandamus to direct the Circuit Court to enter a summary judgment in their favor on certain claims asserted against them by Plaintiffs Dashad Berry, Kamessa Williams, and Miguel Johnson. Plaintiffs' claims stemmed from a traffic stops conducted by the City officers. Each of plaintiffs suffer from a type of paralysis that inhibited their abilities to respond quickly and directly to officers' orders incident to the officers' initial investigations. Plaintiffs sued the City and the individual officers alleging assault and battery, wantonness, negligence, negligent hiring, negligent training and negligent supervision. A trial court entered an order denying the City and officers' motion for summary judgment. On appeal, the City and officers argued they were immune to Plaintiffs' claims. Upon review, the Supreme Court found that Officers Oglesby and McMahon showed a clear legal right to the relief sought, and, as to them, their petition was granted and the trial court was directed to enter a summary judgment in their favor. Officers Stewart, Commander, and Caffey failed to demonstrate a clear legal right to the relief they sought, and, as to them, their petition was denied. However, the City has failed to demonstrate a clear legal right to the relief sought as to the claims against it based on the acts of Officers Stewart, Commander, and Caffey, and its petition was denied as to those claims. Finally, the City has failed to demonstrate a clear legal right to the relief sought based on the claims alleging negligent hiring, training, and supervision, and its petition was denied as to those claims. View "Berry et al. v. City of Montgomery et al." on Justia Law

American Family Care, Inc. (AFC) petitioned the Supreme Court for a writ of mandamus to direct the Jefferson Circuit Court to vacate its order staying a civil action filed by AFC against Anita Salters. Salters was a former employee of AFC, acting as the director of the center from 2007 to June 2010 before her employment was terminated. As director, she was responsible for handling billing issues and claim audits performed by insurance companies and governmental agencies. In some instances, Salters had the only copies of communications related to billing inquiries and claim audits. In April 2011, the Federal Bureau of Investigation executed a search warrant at AFC's corporate office. The FBI removed mostly billing records. After the search warrant was executed, AFC determined that it was missing corporate records it would need to defend itself against any criminal charges that might be filed as a result of the FBI investigation. According to AFC, several of its employees reported that Salters had been seen removing files and records from the corporate offices shortly before she was fired. AFC made written demand upon Salters for the return of the records, but she did not respond. AFC then sued Salters seeking the return of any business records she might have. Salters answered the complaint, denying that she had removed any AFC records from its offices. The trial court, sua sponte, entered an order staying AFC's action "until further notice." The trial court expressed no reason for entering the indefinite stay. Upon review, the Supreme Court found that the indefinite stay ordered by the trial court, with no stated justification for it, was "immoderate" and beyond the scope of the trial court's discretion. For that reason, the Court granted AFC's petition and issued a writ of mandamus ordering the trial court to vacate its order staying AFC's action against Salters. View "American Family Care, Inc., v. Salters" on Justia Law

Following a 1987 conviction for first-degree theft of property and his unsuccessful direct appeal of that conviction, Defendant Joseph Pate filed a Rule 32, Ala. R. Crim P. petition (Rule 32) for relief. The circuit court summarily denied his petition. Defendant filed a second Rule 32 petition in 2010. In the petition, he asserted that: his sentence was illegal because the trial court improperly used two of his prior controlled-substance convictions as sentence enhancements; and, that the State failed to provide notice that it intended to proceed under the Habitual Felony Offender Act for sentence enhancement. The State moved to dismiss, asserting that the petition was barred because those claims could have been, but were not, raised at trial, and because those claims could have been, but were not, raised on appeal. The Court of Criminal Appeals affirmed the circuit court's denial of Defendant's Rule 32 petition without an opinion. On appeal, Defendant contended that in not addressing the denial of his motion for sentence reconsideration the Court of Criminal Appeals incorrectly applied the law to the facts of his case. Because the record supported Defendant's claim that his request for sentence modification was made in a separate motion, the Supreme Court found that the Court of Criminal Appeals erred in concluding that the claim was not proper for appellate review. Accordingly, the Supreme Court reversed the appellate court's judgment to the extent it held that the trial court's ruling on Defendant's request for sentence reconsideration was not properly before it, and remanded the case for the Court of Criminal Appeals to review the circuit court's denial of Defendant's motion for sentence modification. View "Pate v. Alabama" on Justia Law

Defendant Ralph Burnell petitioned the Supreme Court for a writ of mandamus to direct the Bibb Circuit Court to vacate its 2011 order that denied his motion to dismiss claims Plaintiff Christi Burry Kelley filed against him. In 2007 while she was an inmate at the Bibb County jail, Plaintiff slipped in the shower and was injured. Petitioner was the warden of the jail at the time. Plaintiff sued the warden, the jail, the sheriff's department, and the sheriff, alleging negligence and wantonness. Defendants moved to dismiss, arguing among other things that the trial court did not have jurisdiction to hear the claims against them under state immunity. The trial court dismissed as to the County, the jail and the sheriff's department and sheriff, but denied the motion as to Defendant. Defendant argued on appeal to the Supreme Court that he was entitled to State immunity because he was being sued for money damages for actions that arose out of his performance of his duties as a deputy sheriff. Finding that Defendant established a clear legal right to the dismissal of Plaintiff's claims against him, the Supreme Court issued the writ. View "Kelley v. Burnell" on Justia Law