Justia Alabama Supreme Court Opinion Summaries

Chase Andrew Dunn petitioned the Supreme Court for certiorari review of the Court of Criminal Appeals' decision affirming the trial court's revocation of his probation. Dunn pleaded guilty to first-degree assault, and was sentenced to 10 years' imprisonment. That sentence was split, and Dunn was ordered to serve two years' imprisonment followed by three years' probation. Dunn's probation officer filed a delinquency report alleging that Dunn had violated the terms of his probation by: (1) committing the new offense of third-degree robbery; (2) failing to pay court-ordered moneys; and (3) failing to pay supervision fees. The Supreme Court granted Dunn's petition to determine whether the Court of Criminal Appeals' decision conflicted with "Goodgain v. Alabama," (775 So. 2d 591 (Ala. Crim. App. 1999)). The Supreme Court concluded that it did, and therefore reversed and remanded the case for further proceedings. View "Dunn v. Alabama" on Justia Law

R.C.W. was convicted of first-degree rape, first-degree sexual abuse, and two counts of first-degree sodomy. The trial court sentenced R.C.W., pursuant to the Habitual Felony Offender Act, to life imprisonment on the incest and first-degree-sexual-abuse convictions and to life imprisonment without the possibility of parole on the first-degree rape and both first-degree-sodomy convictions. The Court of Criminal Appeals reversed R.C.W.'s convictions in a 3 to 2 decision. The Supreme Court granted the State's petition for a writ of certiorari to determine, as a matter of first impression, whether an erroneous limiting instruction, as to otherwise properly admitted Rule 404(b) collateral-acts evidence, was subject to a harmless-error analysis. In this matter, the Court agreed with the Court of Criminal Appeals that the evidence relating to R.C.W.'s prior sexual misconduct with his daughters was admissible to show motive. Furthermore, the Court agreed that the trial court's limiting instruction was erroneous because it permitted the jury to consider the collateral-acts evidence for issues not in dispute. The Court applied a harmless-error analysis and concluded that any error arising from the trial court's limiting instruction was harmless and was not prejudicial to R.C.W. Accordingly, the judgment of the Court of Criminal Appeals was reversed, and the case remanded for further proceedings. View "R. C. W. v. Alabama" on Justia Law

James Sheffield was indicted on two counts of reckless murder for intentionally setting fire to a cushion he had placed underneath a house that caused a house to catch fire, killing two persons inside the house. Sheffield was convicted of reckless murder on count I (for the death of Charles Morrow, Jr.) and of the lesser-included offense of manslaughter on count II (the death of Charles Morrow III). He was sentenced to 50 years in prison on the reckless murder conviction and to 17 years on the manslaughter conviction, the sentences to run consecutively. Sheffield appealed. On appeal, the Court of Criminal Appeals affirmed the manslaughter conviction on count II but reversed the reckless murder conviction on count I and remanded the case for the circuit court to enter a judgment finding Sheffield guilty of manslaughter on count I and to resentence Sheffield accordingly. On remand, the circuit court entered a judgment convicting Sheffield of manslaughter as to count I. The circuit court then sentenced Sheffield to 17 years' imprisonment for his conviction on count I, the sentence to run consecutively to Sheffield's 17-year sentence on his count II manslaughter conviction. Sheffield appealed again, challenging the sentencing order and contending that the circuit court erred when it imposed consecutive sentences for multiple convictions arising out of a single act. The Court of Criminal Appeals dismissed the appeal on the basis that it lacked jurisdiction to hear an appeal from a sentencing order such as the one at issue here. Sheffield contended on appeal to the Supreme Court, and the State agreed, that the Court of Criminal Appeals had jurisdiction to consider Sheffield's appeal challenging the new sentence imposed by the circuit court on remand. The Supreme Court also agreed, reversed the appellate court and remanded the case for further proceedings. View "Sheffield v. Alabama " on Justia Law

In 2008, a grand jury charged Lam Luong with five counts of capital murder in connection with the deaths of his four children. He was later convicted on all counts, for which he received a death sentence. The Court of Criminal Appeals reversed Luong's convictions and death sentence, 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. The Supreme Court found that the trial court did not abuse its discretion in the decisions it made in this case. As such, the Court reversed the Court of Appeals and remanded this case for further proceedings. View "Luong v. Alabama" on Justia Law

The City of Birmingham appealed a Court of Civil Appeals affirmance of a summary judgment in favor of plaintiff Ernest Alexander in light of the Supreme Court's decision in "Ervin v. City of Birmingham." Upon execution of a search warrant of Alexander's home, federal drug enforcement agents and Birmingham police found marijuana, $38,675 in cash, cocaine, a firearm, and digital scales. In October 2009, a complaint for the civil forfeiture of the $38,675 was filed in the federal district court. Alexander failed to respond to the complaint or to take any action to reclaim the money. The federal court entered a default judgment of forfeiture as to the money on August 10, 2010. On March 16, 2011, Alexander filed a complaint in the Circuit Court seeking the return of the $38,675. He argued that the money had been seized but that no state forfeiture or condemnation proceeding had been filed as required by statute. The City filed a motion to dismiss or, in the alternative, for a summary judgment, arguing, in part, that the trial court did not have jurisdiction over this matter. Based on the intervening change of law set forth in "Ervin," the Court of Civil Appeals' decision in the previous Alexander case ("Alexander I") was "clearly erroneous." Therefore, the Court of Civil Appeals erred when it relied on the law-of-the-case doctrine and on its prior decision in determining that its decision in Alexander I was not subject to appellate review and that the City was not entitled to relief based upon the Supreme Court's decision in Ervin. The Supreme Court reversed the Court of Civil Appeals' judgment and remanded this case for further proceedings. View "City of Birmingham v. Alexander" on Justia Law

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