Justia Criminal Law Opinion Summaries

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

Petitioners-defendants Lt. Harvey Ruffin, a correctional officer at the Bullock Correctional Facility; Sgt. Shelton Patterson, a correctional officer; Sandra Giles, the deputy warden of the facility; and Kenneth Jones, the warden , all petitioned the Alabama Supreme Court for a writ of mandamus to direct the circuit court to grant their motion for summary judgment on immunity grounds. Petitioners were named in a suit brought by an inmate, Thomas Donahey, Jr., who was attacked by another inmate. Donahey alleged that the petitioners negligently, wantonly, and recklessly failed to protect him from the attack. Based on the uncontroverted evidence, the petitioners were entitled to immunity from all the claims asserted against them by Donahey. Accordingly, the petitioners met their burden showing a clear legal right to the relief sought, and the trial court was therefore directed to enter a summary judgment in their favor. View "Donahey, Jr. v. Ruffin" on Justia Law

The issue this case presented for the Supreme Court's review centered on the Court of Criminal Appeals' decision ordering the Limestone Circuit Court to set bail for Joel Moyers. Moyers was charged with a capital offense, and an issue arose over whether a defendant so charged was entitled to bail if the State did not intend to seek the death penalty. The State argued that the Court of Criminal Appeals' decision in this matter conflicted with longstanding Alabama case law ("Ex parte Bynum," 312 So. 2d 52 (1975)). Alternatively, the State argued that the Court of Criminal Appeals' decision raised a material question of first impression that required decision by the Supreme Court. Based on the plain meaning of the statutory and constitutional provisions and the development of the case law in this area, the Supreme Court held that a "capital offense" within the meaning of constitutional and statutory provisions relating to bail is an offense that is punishable by death or by life imprisonment without the possibility of parole. Therefore, when a defendant who is charged with a capital offense requests a trial court to set bail, under Ex parte Bynum, the court can deny that request for bail even if the State will not seek the death penalty. However, in order for the trial court to deny a request for bail from a defendant charged with a capital offense, the State must prove the three prerequisites noted in "Ex parte Patel," (879 So. 2d 532 (Ala. 2003)): "'The evidence must be clear and strong, that it would lead a well-guarded and dispassionate judgment to the conclusion that (1) the offense has been committed; (2) the accused is the guilty agent; and (3) he would probably be punished capitally if the law is administered.'" Moreover, Ex parte Patel held that if a defendant has been indicted for a capital offense, that defendant is presumed guilty for purposes of setting bail, and the defendant has the burden to overcome that presumption before he or she is entitled to bail as a matter of right. The Supreme Court reversed the judgment of the Court of Criminal Appeals and remanded this case for further proceedings. View "Alabama v. Moyers " on Justia Law

Charles Simmons was convicted of a Class A misdemeanor. He appealed the conviction to the Lowndes Circuit Court for a trial de novo. He was convicted and appealed the circuit court's judgment to the Court of Criminal Appeals. The Court of Criminal Appeals reversed the judgment and remanded the case. The State petitioned the Supreme Court for certiorari review of the decision of the Court of Criminal Appeals. The mother of the victim filed a complaint, stating that Simmons, a teacher, had had sexual contact with her daughter, who at the time the sexual contact occurred was under 19 years old. It was undisputed that the mother's complaint was not included in the file forwarded to the circuit court by the district court clerk. An information, however, was filed in the circuit court by the district attorney after Simmons had filed his notice of appeal for a trial de novo. Before the trial in the circuit court commenced, Simmons moved to dismiss the case against him because, he said, the original charging instrument from the district court, the mother's complaint, was not being used to prosecute his case, and he objected to being prosecuted on the information filed by the district attorney subsequent to his conviction in the district court. The circuit court denied his motion, and trial proceeded. Simmons was then convicted. The Court of Criminal Appeals held that, "[i]n the absence of a proper charging instrument, the circuit court could not exercise jurisdiction over Simmons's appeal," and that the circuit court's judgment was void and due to be set aside, and it reversed the judgment and remanded the case. The Supreme Court concluded after its review that the Court of Criminal Appeals erred in holding that the circuit court could not exercise its jurisdiction or that the circuit court's jurisdiction did not attach because the charging instrument from the district court was not used to prosecute Simmons's case in the circuit court. View "Alabama v. Simmons" on Justia Law

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