Capital murder is any murder that makes the defendant eligible for the death penalty. The death penalty, though more common in the United States than other countries, is only awarded as a sentence for the most severe crimes.
In 2004, in Jackson County, in Brownfield v. State of Alabama, the jury convicted James Brownfield of three counts of capital murder and the jury recommended that Brownfield be sentenced to death.
The trial court followed that recommendation. The evidence at trial showed that after consuming Xanax on December 23, 2001, Brownfield attacked his sister, brother-in-law, and sister’s grandson with a claw hammer. Brownfield killed all three. In February 2011, post-sentencing, Brownfield filed a claim for post-conviction relief and the court held an evidentiary hearing on the issues of ineffective assistance of counsel, juror misconduct, and prosecutor misconduct. The court denied his motion and Brownfield appealed.
The Court addressed Brownfield’s arguments from the evidentiary hearing. Brownfield’s first argument is that the trial court was wrong to adopt the State’s proposed order as its final order. However, the Court found that those both orders were similar, the circuit court did examine the findings independently and therefore were not in error.
Brownfield’s next argument was that there was juror misconduct when a certain juror failed to disclose that she had been a victim of a crime. However, there was another crime victim who sat on the jury and half of the prospective jurors were not even asked if they had been a victim of a crime. Therefore, there was no juror misconduct.
Brownfield then argued ineffective assistance of counsel. He argued that his trial counsel was ineffective for not pursuing the defense of intoxication and for not adequately presenting mitigating evidence. However, Brownfield’s attorneys hired clinical psychiatrists and mitigation experts.
The psychiatrist believed Brownfield had falsely confessed which led to a different defense; the mitigation expert quit three weeks before trial which affected the presentation of evidence. The Court agreed with the circuit court that neither of these made Brownfield’s attorneys ineffective.
Brownfield finally argued that his appellate attorneys were also ineffective for advocating for a jury instruction on involuntary intoxication. Because Brownfield failed to ask these attorneys to testify at his hearing, the Court presumed that those attorneys acted reasonably. The Court affirmed the trial court’s judgment.
The main takeaway here is that for a defendant to succeed in receiving a new sentence proceeding, after being convicted of capital murder for three different people, is very difficult. Though Brownfield raised several different arguments, it was a very high threshold to overcome and he was unable to do so. This is a situation that many people sentenced to death will likely find themselves similarly situated.
If you are charged with an Alabama State crime and need a criminal lawyer, you should have an experienced, knowledgeable attorney on your side to make sure that you make the best arguments. Contact INGRAM LAW LLC at (205) 656-0044 for an attorney with the experience and knowledge that can make all the difference.