In this case, Josephus Darnell Boone was convicted in Montgomery Circuit Court of capital murder for firing a weapon from a vehicle, intentional murder as a lesser-included offense of killing a witness in a criminal trial, and discharging a firearm into an occupied building, all arising from the 2017 shooting death of Kelvin Cooley outside a courthouse where Cooley had just testified against Boone's brother. The Alabama Court of Criminal Appeals affirmed the convictions and sentences, which included life without parole for the capital murder. The court reasoned that the State presented sufficient evidence of Boone's guilt based on eyewitness testimony, family animosities tied to prior shootings and drug activity, and Boone's deletion of phone records, while rejecting claims that specific instances of the victim's prior violent acts were admissible under Alabama Rule of Evidence 405(b) as an essential element of a self-defense claim.
The case involved Marco Antonio Perez, who was convicted of capital murder for killing Mobile Police Officer Sean Tuder while the officer was attempting to apprehend him for outstanding warrants. The jury unanimously found the murder was committed to avoid a lawful arrest, an aggravating circumstance, and by an 11-1 vote recommended the death penalty. Perez had raised a pretrial claim of self-defense immunity under Alabama law, which the trial court denied after a hearing, and the case proceeded with the capital charge severed from other counts. On automatic appeal, the Alabama Court of Criminal Appeals reviewed the trial evidence, including video of the shooting, witness testimony, and the penalty-phase presentation of mitigating factors such as Perez's age, ADHD, and remorse. The court affirmed the conviction and death sentence after independently weighing the aggravating and mitigating circumstances and finding the sentence proportionate to similar cases.
William Dale Watson appealed the Limestone Circuit Court's summary dismissal of his 2025 motion challenging his 2017 convictions and sentences for six counts of sexual abuse of a child under 12 and four counts of second-degree sexual abuse. Although the motion was styled as seeking relief under Rule 45 of the Alabama Rules of Appellate Procedure, the Court of Criminal Appeals treated it as a Rule 32 petition for postconviction relief because its substance raised claims cognizable under that rule. The court affirmed the dismissal, holding that the record contained no affirmative indication the circuit court had improperly handled the filing by its label rather than its substance, and that the circuit court was presumed to have followed the law. Watson's claims included alleged plain errors at trial regarding evidence admission, jury instructions, withheld evidence, and lack of personal jurisdiction due to an allegedly forged arraignment waiver.
This case is an appeal by William Chad Randolph challenging his conviction for first-degree rape from the Greene Circuit Court. Following a remand from the Alabama Supreme Court in Ex parte Randolph, the Alabama Court of Criminal Appeals reversed the conviction. The court directed that the case be sent back to the circuit court for further proceedings in line with the Supreme Court's opinion. The decision was joined by all participating judges.
In M.C. v. State of Alabama, the Lawrence Juvenile Court adjudicated M.C. delinquent for making a terrorist threat in the second degree based on a private digital message exchange in which M.C. told another student to 'shoot her first' regarding a teacher, after the other student suggested shooting up the school. The Alabama Court of Criminal Appeals reversed the adjudication and rendered judgment in M.C.'s favor. The court held that the evidence was insufficient under the statutory definition in § 13A-10-240(2), which requires that the statement cause the person to whom it is communicated to fear for their own safety or the safety of the object of the threat. The court reasoned that the recipient, who had initiated the shooting discussion, could not reasonably be shown to have experienced such fear from M.C.'s response.
Lowery Dale Wilson appealed from the Lauderdale Circuit Court's order revoking his participation in the Lauderdale County Community Corrections program after he pleaded guilty to discharging a gun into an occupied building and was placed in the program as part of his sentence. The circuit court granted the State's motion to impose sentence based on Wilson's refusal to sign program paperwork and submit to drug testing, as well as a subsequent arrest. On appeal, Wilson challenged the lack of a proper revocation order and the absence of a hearing transcript. The Alabama Court of Criminal Appeals reversed the revocation order and remanded the case, reasoning that without a transcript of the hearing and a written statement of the evidence relied upon as required by Rule 27.6(f), Ala. R. Crim. P., the court could not review the correctness of the circuit court's actions, consistent with prior precedent.
J.M.M. and A.E.M., husband and wife, were convicted in Russell Circuit Court of aggravated child abuse against their 18-month-old foster child B.N. under Alabama Code § 26-15-3.1(b), resulting in life sentences for each. They appealed their convictions and sentences to the Alabama Court of Criminal Appeals, arguing issues including sufficiency of the evidence and sentencing errors. The court reviewed trial evidence showing the child's severe non-accidental injuries, prior reports of bruises, and medical testimony describing extreme abuse, concluding the evidence supported the verdicts. It affirmed the convictions but remanded for correction of the sentencing orders concerning payment of the state's expert witness costs.
This case involves the consolidated appeals of J.M.M. and A.E.M., a married couple convicted in Russell Circuit Court of aggravated child abuse of their 18-month-old foster child B.N. under Alabama Code § 26-15-3.1(b)(1). The circuit court sentenced each to life imprisonment following a joint trial, and the defendants appealed. The Alabama Court of Criminal Appeals affirmed the convictions, holding that the evidence—including medical testimony on the severity and non-accidental nature of B.N.'s injuries, witness accounts of her condition and prior marks while in the defendants' care, and the defendants' communications with social workers—was sufficient to support the verdicts. The court remanded the cases solely to correct the sentencing orders regarding payment of the State's expert witness costs, noting that the life sentences were within the statutory range for Class A felonies and not challenged on constitutional grounds.
The case involved K.A., a juvenile, who was adjudicated delinquent in Russell Juvenile Court for capital murder committed during a robbery in the first degree after evidence showed he participated in robbing one victim at gunpoint and then fatally shooting another victim minutes later. K.A. appealed the denial of his motion to suppress his confession to police, arguing that as a 13-year-old with limited education he did not knowingly and voluntarily waive his Miranda rights, and also challenged the commitment order sending him to the Department of Youth Services until age 21. The Alabama Court of Criminal Appeals affirmed the delinquency adjudication, concluding that the juvenile court properly found the confession voluntary based on evidence that K.A. nodded in acknowledgment of his rights, signed a waiver, appeared to understand them, and did not invoke counsel or refuse to answer questions. However, the court remanded the case for resentencing because the commitment order failed to comply with the requirements of Ex parte R.E.C. regarding the specific findings and terms for the disposition.
Dexter Rashad Walker was indicted for intentional murder but convicted by a jury of the lesser-included offense of heat-of-passion manslaughter after shooting and killing his son's stepfather at their workplace; he was sentenced to 20 years in prison. Walker appealed, arguing that the trial court erred by denying his motion for a judgment of acquittal on self-defense grounds before he testified (claiming this forced him to waive his Fifth Amendment rights) and by considering his prior arrests during sentencing. The Alabama Court of Criminal Appeals affirmed the conviction and sentence, holding that sufficient evidence supported the jury's rejection of self-defense, that Walker was not compelled to testify, and that a sentencing court may properly consider evidence of prior arrests that did not result in convictions.
In this case, Christopher James Russell appealed the circuit court's summary dismissal of his third Rule 32 petition challenging his 2012 guilty-plea convictions for first-degree robbery and second-degree kidnapping, claiming he was denied his Sixth Amendment right to counsel and counsel of choice during critical stages, including when police obtained his consent to search his phone. The Alabama Court of Criminal Appeals affirmed the dismissal, holding that the consent to search was not a critical stage of the proceedings requiring counsel and that the right-to-counsel-of-choice claim was not jurisdictional and thus time-barred under Rule 32.2(c). The court reasoned that the right to counsel attaches at initial appearance but applies only to critical stages where substantial rights may be affected, and consent to search does not qualify as such even after adversarial proceedings begin. It further noted that structural errors like erroneous deprivation of counsel of choice are not jurisdictional and subject to preclusion rules.
The case concerns Larry Edward Nesbitt's appeal of a Montgomery Circuit Court judgment that revoked his probation. After the Alabama Supreme Court issued an opinion in Ex parte Nesbitt directing further action, the Court of Criminal Appeals reversed the circuit court's revocation order. The court remanded the matter to the circuit court for proceedings consistent with the Supreme Court's opinion.
This case concerns Albert Mack III's Rule 32 postconviction petition challenging his 1995 capital-murder conviction and death sentence for the robbery-related killing of Patrick Holman. The Tuscaloosa Circuit Court granted partial relief, finding that Mack received ineffective assistance of counsel at the penalty phase under Strickland v. Washington and vacated the death sentence, while denying his separate claim that the sentence was unconstitutional because the jury did not make specific findings or reach a unanimous verdict on aggravating and mitigating circumstances. The State appealed the grant of relief, and Mack cross-appealed the denial of his constitutional claim. The Alabama Court of Criminal Appeals affirmed the circuit court's order setting aside the death sentence based on deficient performance and prejudice during sentencing, dismissed the cross-appeal as moot, and held that the jury's 10-2 recommendation and the trial judge's findings complied with applicable law at the time.
Michael Timothy Huff appealed his convictions for first-degree hindering prosecution and reckless manslaughter from the Russell Circuit Court. The Alabama Court of Criminal Appeals affirmed both convictions by an unpublished memorandum. Presiding Judge Windom concurred with the affirmation of the hindering prosecution conviction but dissented from the manslaughter conviction, reasoning that Huff could not have reasonably foreseen the death of Beverly Huff Dunn at the hands of Rhonda Crute.
Brett Tyler Wahlgren was convicted of first-degree domestic violence in Jefferson Circuit Court after he had previously pleaded guilty in district court to third-degree domestic violence for the same physical altercation with his wife. The Alabama Court of Criminal Appeals reversed the conviction on double-jeopardy grounds. The court held that third-degree domestic violence is a lesser-included offense of first-degree domestic violence under Alabama Code § 13A-1-9 because the legislature designated it as a lesser degree of the greater offense. Because both charges arose from the same act or transaction involving the same victim, the prior conviction barred the subsequent prosecution and conviction for the greater offense.
The case involved Terrell Maurice Watts, who was convicted in Jefferson Circuit Court of capital murder for using a deadly weapon fired from a vehicle under Alabama Code § 13A-5-40(a)(18). The evidence showed Watts was the only other person in the backseat of a car with the victim and another individual when a gunshot killed the victim, with no one else observed nearby, a flash seen from the backseat, and Watts fleeing the scene afterward. The trial court sentenced him to life imprisonment without parole after the State did not seek the death penalty. On appeal, the Alabama Court of Criminal Appeals affirmed the conviction, holding that the circumstantial evidence was sufficient for a jury to exclude every reasonable hypothesis except Watts's guilt and that intent to kill could be inferred from his use of a deadly weapon.
Craig L. Newton appealed the Macon Circuit Court's summary dismissal of his Rule 32 petition for postconviction relief, which challenged his 2006 convictions for capital murder during a robbery, first-degree arson, and first-degree theft, along with his death sentence. Newton had been convicted after a jury trial, with the jury recommending death by a 10-2 vote, and his direct appeal had been affirmed years earlier. The Alabama Court of Criminal Appeals affirmed the dismissal, holding that the claims in the amended petition were either procedurally barred, insufficiently pleaded, or without merit, including a claim that non-unanimous jury verdicts violate the Constitution which the court found inapplicable to capital sentencing phases under existing precedent.
In Darryl Bain v. State of Alabama, the defendant pleaded guilty to two counts of unlawful possession of controlled substances but reserved the right to appeal the trial court's denial of his motion to suppress drug evidence found during a warrantless search of his person and vehicle. Police had approached Bain after a report of a suspicious vehicle, detected the odor of marijuana upon waking him, and conducted the search that uncovered methamphetamine and alprazolam pills, though no marijuana was present. Bain argued that Alabama's legalization of hemp, which has an indistinguishable odor, eliminated probable cause based solely on the smell of marijuana. The Alabama Court of Criminal Appeals affirmed the trial court's ruling, holding that the odor of marijuana remains sufficient to establish probable cause for a search under the totality-of-the-circumstances standard, as marijuana possession is still largely illegal and precedent from the Alabama Supreme Court binds the court.
William Chad Randolph was convicted in the Greene Circuit Court of first-degree rape under § 13A-6-61(a)(1) for assaulting his 16-year-old niece at a fish camp trailer in September 2020, based on the victim's testimony describing the incident and resistance along with corroborating evidence from a DHR investigation. The Alabama Court of Criminal Appeals affirmed the conviction and the split sentence of 120 months with 36 months to serve. The majority held that the DHR supervisor's testimony about evidence supporting the allegations was admissible and did not improperly opine on the ultimate issue or require expert qualification, while a dissent contended that the testimony violated Rule 704 by bolstering the victim's account with the agency's approval.
J.D.M. was convicted in Lee Circuit Court of two counts of first-degree sodomy and one count of sexual abuse of a child under 12, receiving consecutive life sentences for the sodomy counts plus 20 years for the abuse count. On appeal, he argued that the circuit court erred by allowing his motion for a new trial—based on claims of ineffective assistance of counsel for failing to investigate mental health issues, witnesses, and evidence—to be denied by operation of law without an evidentiary hearing or findings. The Alabama Court of Criminal Appeals held that under Edgar v. State, the uncontroverted post-trial evidence in support of the motion required reversal of the denial and remand for a hearing with specific written findings on the ineffective-assistance claims.