Justia Alabama Supreme Court Opinion Summaries

Christopher Floyd was convicted for the 2005 murder of Waylon Crawford, for which he was sentenced to death. The Alabama Supreme Court issued a writ of certiorari to determine whether the following holdings of the Court of Criminal Appeals in Floyd's appeal of his capital-murder conviction were proper: that the the trial court did not err in holding that the State provided valid race- and gender-neutral reasons for its exercise of its peremptory strikes during jury selection; that the trial court did not err by refusing to admit into evidence all of Floyd's statements made to law-enforcement officers; and that the trial court did not err in denying Floyd's motion for a new trial based on newly discovered evidence. Finding no reversible error, the Supreme Court affirmed. View "Ex parte Christopher Floyd" on Justia Law

Plaintiff James Freeman, a parolee whose earlier parole from a life sentence for murder was revoked, appealed a trial court's dismissal of his claims against the City of Birmingham; Birmingham Police Officer Dewayne Holyfield, Charles W. Edwards; and Alma Berry, alleging false arrest, false imprisonment, and conspiracy. Freeman was convicted of first-degree murder in 1975, and was sentenced to life in prison. He was granted parole in 1993. In 1995, Officer Holyfield responded to a complaint that a man was beating a female near 14th Avenue North in Birmingham. Officer Holyfield drove to that address and discovered a female whose neck had been scratched and whose eyes were blackened and swollen. She claimed that Freeman had attacked her. Based on this incident, a warrant was issued the next day for Freeman's arrest. He was arrested and charged with "domestic assault" hours after the warrant was issued. As a result of the arrest, Edwards, then the executive director of the Alabama Board of Pardons and Paroles, initiated parole-revocation proceedings against Freeman. Berry was the parole-revocation hearing officer at the proceedings. Berry found sufficient evidence to support the charge of domestic assault against Freeman, and recommended the revocation of Freeman's parole. A member of the Board of Pardons and Paroles adjudged Freeman guilty of domestic assault and revoked his parole. At the time his parole was revoked, no court had adjudged Freeman guilty of domestic assault. Freeman was incarcerated and remained in prison until March 7, 2011, when he was again released on parole. From 1995 to 2011, Freeman was denied parole six times, based in part, he alleges, on his having committed the offense of domestic assault, of which he had never been convicted. In 2012, Freeman reported to the municipal court in Birmingham "to address the 1995 charge of 'domestic assault.'" He claimed that, when he arrived at the municipal court, he learned for the first time that the 1995 charge was assault and battery and not domestic assault. Freeman filed this suit in 2014, more than 18 years after the revocation of his parole in 1995 and 2 years, 11 months, and 29 days after he appeared in the municipal court in Birmingham and allegedly learned of the assault-and-battery charge against him. After review of Freeman's arguments on appeal of the trial court's dismissal of his claims, the Supreme Court found no reversible error, and affirmed the dismissal of those claims. View "Freeman v. Holyfield" on Justia Law

In August 2000, when Jimmy Williams, Jr. was 15 years old, he was convicted of murder made capital because it was committed during a robbery. In accordance with the applicable law at the time of Williams's sentencing, the trial court sentenced Williams to life imprisonment without the possibility of parole, the only possible sentence and one that was mandatory. The Court of Criminal Appeals affirmed Williams's conviction and sentence. In June 2013, Williams petitioned the circuit court, asserting that under the rule announced by the United States Supreme Court in "Miller v. Alabama," (132 S.Ct. 2455 (2012)), the mandatory sentence of life imprisonment without the possibility of parole to which he was sentenced in 2000 for an offense committed when he was 15 years old was unconstitutional and, consequently, that he was entitled to be resentenced based on the individualized sentencing factors discussed in Miller. The issue in this case presented for the Alabama Supreme Court's review was whether "Miller" applied retroactively to Williams' case. Because Miller did not categorically forbid a sentence of life imprisonment without parole for a juvenile defendant and because Miller did not apply retroactively, Williams's sentence of life imprisonment without the possibility of parole was legal. The Alabama Supreme Court concluded the Court of Criminal Appeals did not err in denying Williams the relief he requested. View "Ex parte Jimmy Williams, Jr." on Justia Law

John Harper, an incarcerated inmate, petitioned the Alabama Supreme Court to review the circuit court's denial of his latest motion for sentence reconsideration. Harper was convicted in 1986 of first-degree armed robbery. Based on that conviction and a prior felony conviction, the circuit court sentenced him as a habitual felony offender to what in 1986 was a mandatory life sentence without the possibility of parole. Because the circuit court did not consider all the factors and evidence, including records of the Department of Corrections, that Harper presented with his "Kirby" motion, the Supreme Court concluded that the circuit court did not consider the totality of the circumstances. For the same reasons, the Court of Criminal Appeals erred in affirming the circuit court's order denying Harper's Kirby motion. The Supreme Court therefore reversed the Court of Criminal Appeals' judgment and directed that court to remand the case to the circuit court for it to reconsider Harper's Kirby motion. "We note in conclusion that the window for the review of Kirby motions has been closing since the repeal of 13A-5-9.1, effective March 1, 2014. After 28 years of incarceration, Harper is faced with his last opportunity to take advantage of 13A-5-9.1. He has done exactly what a previous court said he must do for reconsideration of his sentence as a current nonviolent convicted offender. Justice demands that he have an opportunity provided by that law for reconsideration of his sentence." View "Ex parte John Alfred Harper." on Justia Law

Howard Carl Whited was convicted of sodomy in the first degree. The trial court sentenced Whited to 35 years' imprisonment and ordered Whited to pay $50 to the Alabama Crime Victims Compensation Fund and court costs. The Court of Criminal Appeals affirmed Whited's conviction and sentence in a 3-2 per curiam opinion. Whited petitioned the Alabama Supreme Court for a writ of certiorari, contending that the decision of the Court of Criminal Appeals conflicted with "Strickland v. Washington," (466 U.S. 668 (1984)). After evaluating "all the circumstances surrounding the case at the time of [Whited's] counsel's actions," including Whited's trial counsel's inability to provide a strategic reason for waiving closing argument; the seemingly strong arguments available to Whited from which the jury could possibly conclude that reasonable doubt existed as to Whited's guilt; and the length and highly emotional nature of the State's initial closing argument, the Supreme Court concluded that trial counsel's decision to waive closing argument was an "error[] so serious that counsel was not functioning as the 'counsel' guaranteed the defendant by the Sixth Amendment" and that the waiver of Whited's closing was deficient under "Strickland." Furthermore, had trial counsel presented a closing argument to the jury, "there is a reasonable probability that ... the result of the proceeding would have been different." The Alabama Court granted the petition, reversed and remanded the case for a new trial. View "Ex parte Howard Whited." on Justia Law

The State of Alabama petitioned for a writ of mandamus to direct the Pike Circuit Court to vacate its order granting Andre Ellis's motion for a new trial. Ellis was convicted on two counts of first degree rape, and burglary in the second degree. He received an 85-year sentence. Ellis moved for a new trial, alleging, among other things, that the State had failed to disclose crucial evidence in violation of "Brady v. Maryland," (373 U.S. 83 (1963)). The trial court ordered the State to disclose in camera certain evidence and, after conducting a hearing, entered an order dated May 17, 2013, granting Ellis's motion for a new trial based on the State's failure to turn over evidence in violation of Rule 16, Ala. R. Crim. P., and in violation of the principles of law set forth in "Brady." The State moved for consideration, on which the trial court did not rule. The State argued in its petition for mandamus that the trial court exceeded its discretion and its judicial authority in granting Ellis a new trial because the trial court improperly combed the prosecutor's files and incorrectly and improperly analyzed the contents in those files. The State also argued that the trial court exceeded its discretion in granting a new trial because Ellis never laid the proper predicate to compel the State to disclose the statements of the victims as required by state case law. Lastly, the State argued that the trial court exceeded its discretion in entering its order granting a new trial with regard to the rape charge involving one of the victims because Ellis made no allegation in his motion for a new trial regarding a discovery violation in the case in which that victim was the named victim nor did the trial court make any findings as to any alleged discovery violation pertaining to that case. Upon further review, the Supreme Court concluded the State failed to present exceptional circumstances justifying the issuance of a writ to direct the trial court to set aside its order granting Ellis's motion for a new trial. View "Alabama v. Ellis" on Justia Law

In an unpublished order, the Court of Criminal Appeals issued a writ of mandamus directing the trial court in the underlying case to "bar" the prosecution of respondent Margie Kelley, who had been indicted for three counts of capital murder. The State petitioned the Supreme Court for a writ of mandamus to direct the Court of Criminal Appeals to vacate its order. The Court of Criminals Appeals relied on the decision of "Davenport v. Alabama," (968 So. 2d 27 (Ala. Crim. App. 2005)) in arriving at its conclusion. In its mandamus petition, the State contended that "Davenport," in holding that an individual cannot be prosecuted for hindering the prosecution of another when the individual was also a principal, or participated, in that crime, misstated the law. The Supreme Court agreed. As such, the State met its burden for mandamus relief, and the Supreme Court granted its petition and issued the writ. View "Alabama v. Kelley" on Justia Law

Kevin Towles was convicted of capital murder for killing his son, Geontae Glass, who was under the age of 14 when he was killed. The jury recommended the death sentence, and the trial court sentenced Towles to death. The Court of Criminal Appeals reversed Towles's conviction and sentence in a per curiam opinion. The State petitioned for certiorari, arguing the Court of Criminal Appeals erred in reversing Towles's conviction based on the admission of certain testimony by Towles' other son, because the testimony was relevant and admissible to prove Towles's motive for killing Geontae. The State further argued that the Court of Criminal Appeals erred in failing to apply a harmless-error analysis to the trial court's erroneous limiting instruction, which allowed the jury to consider Towles's collateral bad acts for improper purposes. Towles contends that the Court of Criminal Appeals did not err in determining that Cameron's testimony was inadmissible to show motive because, he says, there was no logical or factual connection between Geontae's killing and the incidents of abuse testified to by Cameron. In this case, the Supreme Court found that the prior bad acts of assault and physical abuse were not perpetrated by Towles upon the victim Geontae. Rather, the prior assaults and abuse were perpetrated upon Cameron approximately three years before Geontae's murder. "We cannot say that Cameron's testimony relating to the physical assaults he suffered at the hands of Towles approximately three years before Geontae's murder was relevant to show that Towles intended to kill Geontae. Further, where the jury was faced with deciding whether Towles intended to murder Geontae or to assault him for disciplinary issues at school, the admission of the collateral assaults perpetrated by Towles upon Cameron were highly prejudicial. The probative value, if any, of the testimony concerning the collateral assaults upon one son simply does not outweigh the undue prejudice to Towles in his prosecution for the capital murder of his other son." Accordingly the trial court's admission of the collateral-acts testimony to show intent and its limiting instruction to the jury that the jury could consider the testimony for purposes of establishing intent constituted plain error. Accordingly, the Court affirmed the Court of Criminal Appeals. View "Towles v. Alabama" on Justia Law

In February 2008, a Mobile County grand jury charged Lam Luong with five counts of capital murder in connection with the deaths of his four children. Luong killed his four children by throwing them off a bridge into water 100 feet below the bridge. The trial court sentenced Luong to death for each of the five capital-murder convictions. The Court of Criminal Appeals reversed Luong's convictions and death sentences, holding that the trial court erred by refusing to move the trial from Mobile County because, it reasoned, the pretrial publicity was presumptively prejudicial and by refusing to conduct individual questioning of the potential jurors regarding their exposure to that publicity. The Court of Criminal Appeals also held that the trial court erred in denying defense counsel funds to travel to Vietnam to investigate mitigation evidence and in admitting into evidence during the sentencing hearing a videotape simulation using sandbags approximately the weight of each child illustrating the length of time it took for each child to fall from the bridge to the water. After careful consideration of the trial court record, the Supreme Court held: (1) the trial court did not exceed the scope of its discretion in refusing to find presumed prejudice against Luong and refusing to transfer his case on that basis; (2) the trial court did not exceed the scope of its discretion in denying Luong's request that the trial court conduct individual voir dire; (3) and because the record established that the trial court considered the reasonableness of Luong's request and provided a means for Luong to develop mitigation evidence, the trial court did not exceed the scope of its discretion in denying Luong's request for funds for his counsel to travel to Vietnam to investigate mitigation evidence; and (4) the trial court did not exceed the scope of its discretion in admitting certain videotape evidence. Accordingly, the court of Criminal Appeals was reversed. View "Luong v. Alabama" on Justia Law

Criminal defendants Clement Poiroux, Lamar Osborne, Travis Blair, Christopher Raybon, Sara Hawkins, Brian Williams, Levorish Hudson, Joseph Johnson, Jr., Nicholas McNeil, and Willie Walker II, and McNeil & Stokley Enterprises, LLC, d/b/a Metro Bonding Co., Bay Area Bail Bonds, LLC, A-Plus Bonding, Inc., Alternative Justice Bail Bonding, Inc., A-Advantage Bonding, LLC, Affordable Bail Bond, Inc., and Allstar Bail Bonds, Inc. appealed the dismissal of their claims against various district attorneys, circuit court clerks, and other state officials. Several of the criminal defendants and of the bail-bond companies sued the defendants and fictitiously named parties alleging claims related to Act No. 2012-535, Ala. Acts 2012 (codified as 12-14-31 and 12-19-311, Ala. Code 1975). The criminal defendants and the bail-bond companies argued, among other things, that the fee assessed pursuant to 12-19-311(a)(1)a., Ala. Code 1975 ("the filing fee"), and the fee assessed pursuant to 12-19-311(a)(1)b., Ala. Code 1975 ("the back-end fee"), were unconstitutional. Upon review of the circuit court record, the Supreme Court affirmed the dismissal of all claims regarding the back-end fees, all claims seeking monetary relief, and all claims against the defendant sheriffs. The Court also affirmed the dismissal of the criminal defendants' claims for declaratory and injunctive relief. The Court reversed the circuit court's judgment insofar as it dismissed the bail-bond companies' claims for declaratory and injunctive relief against the defendants other than the defendant sheriffs. View "Poiroux v. Rich" on Justia Law