In the Court of Criminal Appeals

(Requirements of Ala. Code 1975, Section 15-8-25)

In this matter, the Court held that requirements of the above-stated theft statute are satisfied by identification of monetary amount alone.  Court held that identification of the monetary amount now provides the defendant adequate notice of theft to prepare defense and to avoid double jeopardy.

In the Court of Criminal Appeals

(Ala. Code 1975, Section 32-5A-191)

In this matter, the Court held that municipal DUI convictions are not convictions under the above-stated code section and are not subject to the enhancements of 32-5A-191(h). 

In the Alabama Supreme Court

(Sixth Amendment Right to Continued Representation)

In this matter, the Court held that an indigent defendant does not have a right to continued representation by the same counsel in another matter. Right to counsel of choice does not extend to defendants who require counsel to be appointed.

In the Alabama Supreme Court

(Evidence of “Serious Bodily Injury”)

In this matter, the Court held that evidence of a scar was sufficient to demonstrate injury needed to sustain a conviction for first degree assault even in the absence of medical testimony or testimony from the victim. The Court stated that a lay witness who has observed the victim’s wound, the resulting scar and has knowledge of recovery from injury is able to present sufficient evidence as to whether the victim has suffered a “serious and protracted disfigurement.”