Justia Alabama Supreme Court Opinion Summaries

Christopher Floyd was convicted of capital murder in 2005 for the death of Waylon Crawford, for which he was sentenced to death. The Alabama Supreme Court granted certiorari review of Floyd's appeal to determine whether the following holdings of the Court of Criminal Appeals were proper: (1) that 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; (2) that the trial court did not err by refusing to admit into evidence all of Floyd's statements made to law-enforcement officers; and (3) 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 Anthony Floyd." on Justia Law

The Alabama Supreme Court issued a writ of certiorari to address the State's request that it overrule "Ex parte J.A.P.," (853 So. 2d 280 (Ala. 2002)), the controlling precedent applied by the Court of Criminal Appeals in reversing Eric Higdon's conviction for first-degree sodomy by forcible compulsion. "In overruling 'Ex parte J.A.P.,' this Court returns to an approach more consonant with the statutory definition of forcible compulsion and the principles set forth in a 'Powe [v. Alabama, (597 So.2d 721 (Ala. 1991))]' in conducting a forcible-compulsion analysis when a defendant, regardless of his or her age, exercises a position of domination and control over a child." The judgment of the Court of Criminal Appeals was reversed, and this case remanded for further proceedings. View "Ex parte State of Alabama." on Justia Law

In August 2011, Teddy Knox was driving along Interstate 59 in Fort Payne. Officer Matt Wilson of the Fort Payne Police Department stopped Knox's vehicle for improper lane use. During the stop, Officer Wilson became suspicious that Knox might be transporting drugs, and he requested backup from Officer Tony Blackwell, who was a member of the county drug task force and who had his drug-detection dog with him. Lt. Randy Garrison, another member of the drug task force, was also en route to the scene. Officer Wilson eventually issued a warning citation to Knox and told him that he was free to go, but he continued to question Knox about his travel plans. Lt. Garrison and Officer Blackwell arrived at some point during the questioning of Knox. After Officer Blackwell arrived with his dog, Officer Wilson asked Knox if he would consent to a search of his vehicle. Knox refused to consent, and Officer Blackwell then deployed his dog to perform a free-air sniff. The dog "indicated" for the odor of marijuana, and the police eventually searched the vehicle and discovered marijuana. The police seized in excess of 2.2 pounds of marijuana and arrested Knox for trafficking in marijuana, unlawful possession of marijuana, and first-degree unlawful possession of drug paraphernalia. Knox filed a motion to suppress the evidence of the marijuana seized during the traffic stop. After an evidentiary hearing, the circuit court entered a written order granting the motion to suppress. The State appealed; the Court of Criminal Appeals reversed the judgment on a ground not raised in the circuit court: that Knox was no longer being detained at the time the search was executed. The Supreme Court reversed and remanded, surmising that it was likely that the State's failure to raise the absence-of-detention argument before the circuit court may have deprived Knox of an opportunity to present evidence in opposition to that theory. "The primary focus of the suppression hearing was the existence of reasonable suspicion, which was based largely on the police officers' observations. Had the State raised the absence-of-detention argument in the circuit court, it is possible that Knox might have chosen to present evidence as to (1) whether he felt free to leave the scene after he was given his warning citation and (2) whether there was a showing of authority sufficient to constitute a detention. By failing to raise this new issue at trial, the State deprived Knox of an opportunity to present evidence and to make arguments. The State's failure to raise the issue also deprived the circuit court of the opportunity to make factual findings and credibility determinations on this issue." View "Ex parte Knox." on Justia Law

Inmate Charleton Thomas petitioned for postconviction relief, which the circuit court summarily dismissed. The Court of Criminal Appeals, by unpublished memorandum, affirmed the summary dismissal of Thomas's petition, concluding that Thomas's Rule 32 petition was untimely because, at the time he filed his Rule 32 petition, Thomas had not paid the filing fee or filed a request to proceed in forma pauperis. Upon review, the Supreme Court reversed and remanded, finding that the evidence in the record created a question of material fact as to whether Thomas's in forma pauperis declaration was filed with his Rule 32 petition, so as to render the Rule 32 petition timely. View "Ex parte Thomas." on Justia Law

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