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Prior Guilty Plea Not Admissible in Montgomery County, Alabama


This is a criminal case from Montgomery County, Alabama, in the case of Woods v. State of Alabama. In June 2013, Alabama State Trooper Thomas Hutton (“Hutton”) observed Otha Woods (“Woods”) driving on Interstate 65. Hutton testified that Woods was speeding and changing lanes without signals. After witnessing the traffic violations, Hutton initiated a traffic stop. When Hutton approached the vehicle, Hutton smelled alcohol. Hutton then initiated a field sobriety test, which Woods was unable to pass. Accordingly, Hutton placed Woods under arrest and for driving while under the influence of alcohol (“DUI”).

A subsequent breathalyzer test, which was administered three hours later, indicated that Woods had a blood alcohol content level of .08. Woods plead guilty in the district court to DUI. He appealed to the circuit court for trial de novo, where he was convicted of DUI by a jury. Accordingly, Woods appealed for a second time.

Here, the Court of Criminal Appeals addressed whether the trial court erred when it admitted into evidence a redacted copy of the sentencing order in Wood’s guilty plea conviction in district court. The state argued that this issue was not reserved for appellate review. Before the trial, Woods moved to exclude evidence of his district court guilty plea. A discussion took place regarding the admissibility of such evidence; however, no formal ruling was made in regards to the admissibility of the evidence.

Subsequently, when the State tried to introduce a copy of the State’s sentencing order, defense counsel objected. Despite the defense’s objection, the trial court admitted the redacted copy of the sentencing order and published it to the jury. Further, at trial Woods admitted that he was drunk at the time Hutton stopped him; however, Woods attributed his high blood-alcohol level to his use of Albuterol. The prosecutor then asked him if he plead guilty to a DUI in district court. Woods stated that the he had “accepted it, because my lawyer told me to.” Defense counsel objected to that line of questioning.

Previously, the Court of Criminal Appeals held that a guilty plea in a lower court is admissible in a circuit court trial “because a guilty plea is a judicial confession or an admission against interest.” Phillips v. City of Dothan, 534 So. 2d 381 (Ala. Crim. App. 1988). In Phillips, the Court of Criminal Appeals held that the trial court did not err by allowing the prosecution to cross-examine the defendant about his previous guilty plea in municipal court. Id. However, in this instance, the Court of Criminal Appeals concludes that Phillips violates well-known principles of law regarding trial de novo. The Court of Criminal Appeals concluded that trial de novo means, “the slate is wiped cleaned.” Upon further examination, the Court of Criminal Appeals concluded that allowing such evidence, such as a past conviction in a lower court, would be highly prejudicial.

Notably, courts are reluctant to reverse precedent. Precedent is a legal decision that serves as an authoritative rule or pattern for future similar cases. Precedent has a long-standing history in the American court system and provides a basis for many court decisions in this country. However, that was not the situation for the case at hand. Here, the Court of Criminal Appeals overruled a 28-year long precedent. The Court of Criminal Appeals ruled that the current case law directly opposed well-settled principles of law regarding trial de novo; as a result, it was the Court of Criminal Appeals duty to reverse the order and apply the proper analysis.

If you need a Birmingham criminal defense lawyer, contact Joseph A. Ingram or Ingram Law LLC at (205) 335-2640..

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