Justia Criminal Law Opinion Summaries

Dalen Gaines sought monetary and equitable relief against Walker County law-enforcement officers for their role in what Gaines claimed was a delayed bond hearing. After Gaines failed to appear at the Walker Circuit Court to answer criminal charges, the court issued a warrant for his arrest. Three months later, Walker County Sheriff's Deputy Christopher Doeur executed the warrant and took Gaines into custody. Afterward, Deputy Doeur filed a certificate of execution, informing the Circuit Court that he had arrested Gaines and placed him in the County jail. After about a month, Gaines remained incarcerated and had not yet appeared in court. The trial court granted the law-enforcement officers' motion to dismiss Gaines complaint here, and Gaines asked the Alabama Supreme Court to overturn that decision. The Court declined to do so, and affirmed dismissal. View "Gaines v. Smith" on Justia Law

Dennis Morgan Hicks was convicted of one count of capital murder for the killing of Joshua Duncan. The murder was made capital because Hicks committed it while he was under a sentence of life imprisonment. Hicks was also convicted of one count of second-degree theft of property. By a vote of 11-1, the jury recommended that Hicks be sentenced to death on the capital-murder conviction. The Circuit Court followed the jury's recommendation and sentenced Hicks to death on the capital-murder conviction; it sentenced him to time served on the second-degree theft-of-property conviction. Hicks appealed to the Alabama Court of Criminal Appeals, and, on original submission, that court affirmed Hicks's conviction but remanded the case for the trial court to address some sentencing issues. The Court of Criminal Appeals ultimately affirmed the death sentence. To the Alabama Supreme Court, Hicks argued the Court of Criminal Appeals erred: (1) in holding his right to counsel was not violated at the time of a pretrial mental evaluation; and (2) in holding that Dr. Karl Kirkland's testimony regarding Hicks' pretrial mental evaluation was admitted properly. Finding no reversible error, the Supreme Court affirmed the appellate court's judgment. View "Ex parte Dennis Morgan Hicks." on Justia Law

After being indicted by a grand jury for unlawful possession of a controlled substance -- delta-9- tetrahydrocannabinol (synthetic marijuana), Charlie Byrd filed a motion to suppress the evidence that was the basis of his indictment on the ground that it was the product of an unlawful search and seizure. The motion was denied, and Byrd conditionally pled guilty, reserving the right to appeal the denial of the motion to suppress. Byrd was sentenced to 60 months in prison, with 12 served and 24 months of supervised probation. The Court of. Criminal Appeals affirmed Byrd’s conviction, and he appealed to the Alabama Supreme Court. Finding no reversible error, the Supreme Court affirmed the Court of Criminal Appeals. View "Ex parte Charlie Byrd" on Justia Law

In January 2018, Whitney Jones, an inmate in the Mobile County Metro Jail and a participant in the jail's work-release program, left her work-release job and did not return to the work-release barracks. As a result, Jones was charged with, and convicted of, second-degree escape, a felony. The Alabama Court of Criminal Appeals affirmed Jones's conviction. The Alabama Supreme Court granted certiorari review to consider whether an inmate, like Jones, who escapes from a county work-release program authorized pursuant to Ala. Code 1975, §§ 14-8-30 through 14-8-44 ("the county work-release statutes"), could be convicted of escape pursuant to one of the escape statutes in the Alabama Criminal Code, Ala. Code 1975, §§ 13A-10-30 through 13A-10-33 ("the escape statutes"), which would be punishable as a felony, or whether such an escape is punishable only as a misdemeanor pursuant to Ala. Code 1975, §§ 14-8-42 and 14-8-43. The Supreme Court concluded that escapes from county work-release programs were governed by the escape statutes. Accordingly, the Court affirmed the judgment of the Alabama Court of Criminal Appeals. View "Jones v. Alabama" on Justia Law

In January 2018, Whitney Jones, an inmate in the Mobile County Metro Jail and a participant in the jail's work-release program, left her work-release job and did not return to the work-release barracks. As a result, Jones was charged with, and convicted of, second-degree felony escape. The Alabama Court of Criminal Appeals affirmed Jones's conviction. The Alabama Supreme Court granted certiorari review to consider whether an inmate, like Jones, who escapes from a county work-release program authorized pursuant to Ala. Code 1975, §§ 14-8-30 through 14-8-44 could be convicted of escape pursuant to one of the escape statutes in the Alabama Criminal Code, Ala. Code 1975, §§ 13A-10-30 through 13A-10-33 ("the escape statutes"), which would be punishable as a felony, or whether such an escape was punishable only as a misdemeanor pursuant to Ala. Code 1975, §§ 14-8-42 and 14-8-43. The Supreme Court concluded that escapes from county work-release programs were governed by the escape statutes. View "Ex parte Whitney Owens Jones." on Justia Law

Hunter Halver Brown petitioned the Alabama Supreme Court for certiorari review in which a circuit court had denied Brown's motion to dismiss the indictment against him notwithstanding the State's purported failure to comply with the Uniform Mandatory Disposition of Detainers Act, 15-9-80 et seq., Ala. Code 1975 ("the Act"), a codification of the federal Interstate Agreement on Detainers, 18 U.S.C. App. 2 ("the IAD"). The Supreme Court granted certiorari review to consider whether, as a matter of first impression, its Court's statewide suspension of jury trials in response to the COVID-19 pandemic tolled the Act's 180-day time limit for bringing a prisoner to trial. The Court held that it did, and affirmed the Court of Criminal Appeals' decision to affirm the circuit court. View "Ex parte Hunter Halver Brown." on Justia Law

The issue this case presented for the Alabama Supreme Court's review was one of first impression. Yamil Alexsander Hare and Jose Sosa filed a state-court action to recover personal property that a Gulf Shores police officer seized without a warrant under state law and then transferred to two Baldwin County Sheriff's Office ("BCSO") deputies, acting in their capacity as federally deputized agents of the Drug Enforcement Administration ("the DEA"). The circuit court ruled that it lacked in rem jurisdiction based on the Court of Civil Appeals' caselaw. The Supreme Court held that, under 21 U.S.C. 881(c), exclusive federal jurisdiction attached when the deputized DEA agents took possession of the property and no state court had prior in rem jurisdiction. Accordingly, the Supreme Court affirmed the circuit court. View "Hare v. Mack" on Justia Law

In 2018, pursuant to a premises search warrant, police in Mobile, Alabama searched the residence of Joshua Moyers, seeking evidence of drug activity. Although Moyers was referenced in the affidavit supporting the issuance of the warrant, no individuals were named in the warrant itself. Police entered Moyers's house and discovered Nancy Powers sleeping on a couch in the first room of the house. Powers's purse was sitting on a table next to the couch. After confirming with Powers that the purse belonged to her, police searched the purse and discovered methamphetamine, a digital scale, and cash. Relevant to these proceedings, Powers was charged with possession of methamphetamine with intent to distribute. The circuit court denied Powers's motion to suppress the evidence found in her purse. Thereafter, Powers pleaded guilty and appealed to the Court of Criminal Appeals, challenging the trial court's denial of the motion to suppress. The Court of Criminal Appeals unanimously affirmed the trial court's ruling. The Alabama Supreme Court granted Powers's petition for a writ of certiorari to consider a question of first impression: whether police improperly searched Powers' purse, or whether, as the State argued, the purse was simply a container in the House that fit within the scope of the premises warrant. The Supreme Court agreed with the State that the purse was a container that came within the scope of the warrant, and that Powers' right to privacy was not violated. View "Ex parte Nancy Powers." on Justia Law

Sherman Collins petitioned the Alabama Supreme Court for certiorari review of the Court of Criminal Appeals' judgment affirming Collins's convictions for capital murder for the intentional killing of Detrick Bell for pecuniary gain, and for criminal conspiracy. The appellate court also affirmed his resulting sentences of death for his capital-murder conviction and of 120 months' imprisonment for his criminal-conspiracy conviction. The Supreme Court granted review to consider whether the Court of Criminal Appeals' decision was in conflict with Blockburger v. United States, 284 U.S. 299 (1932); the Alabama Court concluded that it was. As a result, the Supreme Court affirmed the Court of Criminal Appeals' decision insofar as it affirmed Collins's capital-murder conviction and his resulting death sentence, but reversed the decision insofar as it affirmed Collins's criminal-conspiracy conviction and his resulting sentence to 120 months' imprisonment. The case was remanded to the Court of Criminal Appeals to remand the cause to the trial court to set aside Collins's criminal-conspiracy conviction and resulting sentence. View "Ex parte Sherman Collins" on Justia Law

Johnny Lee Self petitioned the Alabama Supreme Court for review of a Court of Criminal Appeals' decision to affirm the summary dismissal of his petition for postconviction relief. In September 2003, Self pleaded guilty to two counts of first-degree sexual abuse, and was sentenced to 25 years' imprisonment; the crime of sexual abuse in the first degree was a Class C felony. Self did not appeal. In 2019, Self petitioned to challenge his convictions and sentences, arguing he had been improperly sentenced to serve 25 years in prison because the maximum sentence authorized for a Class C felony was 10 years, and, Self asserted, he "was not sentenced as a [h]abitual [o]ffender." Self also alleged "that nothing in the record shows that his sentence was properly enhanced." In 2020, the State responded, arguing Self's claim was not a jurisdictional claim, and was barred by the limitations period set forth in Rule 32.2(c), Ala. R. Crim. P. The circuit court summarily dismissed Self's Rule 32 petition, interpreting Self's claims in his Rule 32 petition as (1) a claim "that the State failed to adequately prove [Self's] prior felony convictions that were used to enhance his sentence" and (2) a claim "that the record does not reflect application of the Habitual Felony Offender Act." The Supreme Court granted certiorari review to consider whether the Court of Criminal Appeals' decision was in conflict with Barnes v. State, 708 So. 2d 217 (Ala. Crim. App. 1997), the facts of which were similar to those presented in this case. After review, the Supreme Court concluded the Court of Criminal Appeals' decision was in conflict with Barnes, thus reversing the Court of Criminal Appeals' judgment. View "Ex parte Johnny Lee Self" on Justia Law