In a case that defines the evidentiary standard in criminal trials, the Alabama Court of Criminal Appeals recently heard an appeal from a Tuscaloosa County case. This case, Tavaris Deshon Wilder v. State of Alabama, clarifies the State’s evidentiary burden, solidifying the judicial treatment of circumstantial evidence when compared to direct evidence.
On April 30, 2019, two women got into a fight. Tavaris Deshon Wilder was among the crowd of onlookers and had a child with one of the women in the fight. When the other woman was on top of the mother of his child, Wilder intervened. In the chaos, someone cried out that Wilder had a gun. Several people fled to a car, and the shooting began. Wilder admitted that the gun was his but insisted that another person took his gun and fired it at the car. Investigation pointed to Wilder at the culprit, however, and he was convicted for discharging a firearm into an occupied vehicle and second-degree assault. Wilder was sentenced to 20 years’ imprisonment for the first conviction and 10 years’ imprisonment for the second, with the second sentence being split.
Wilder’s appeal focused on two primary claims: that the trial court erred in denying his motion for a judgment of acquittal due to insufficient evidence; and that the trial court denied his right to a full and complete defense.
In addressing Wilder’s first claim, the Court clarified the standard to obtain and sustain a criminal conviction. In Alabama, circumstantial evidence has been held as sufficient to support a guilty verdict, so long as the evidence causes the jury to believe that the accused is guilty beyond a reasonable doubt. Although Wilder was correct in asserting that no witnesses saw him fire the gun, the State had strong circumstantial evidence indicating his guilt, including his presence at the scene, the use of his gun in the shooting, and Wilder’s personal connection to the fight. The Court found that this evidence was sufficient for the jury to reach their verdict.
Wilder’s second claim centered around the idea that the State had restricted inquiries into an alternate suspect. Wilder claimed another man had taken his gun and fired it, but this claim was not raised at trial. Therefore, the Court found that the issue was not able to be raised on appeal. Further, the trial court had permitted defense counsel to question the investigating officer as to the potential involvement of the alternate suspect. Wilder did not raise any specific questions that had been prohibited by the trial court.
Despite Wilder’s failings on his two claims, his case was still remanded for corrections to Wilder’s sentencing. When a sentence is illegal, and goes beyond what is allowable, courts have the authority to correct the error without the issue being raised by either party. Wilder had previously been sentenced to 5 years of supervised probation following his sentence, but the maximum probation allowed for his offense was three years. Therefore, his probation period needed to be reduced.
Tavaris Deshon Wilder v. State of Alabama demonstrates the application of the “beyond a reasonable doubt” standard, illustrating the breadth of evidence that can be used to meet such a bar. Although the primary evidence against Wilder was circumstantial, the jury was still allowed to find Wilder guilty because the burden of proof was still met. Despite the Court ruling against Wilder in his claims, Wilder was still granted some relief from his excessive probation, highlighting the principle that certain rights are safeguarded throughout the criminal process. Even after being found guilty, criminal defendants are entitled to fair sentencing.
If you have a Federal Criminal case, a State Criminal case, a Municipal Case or a Family Law case, contact Joe Ingram or Ingram Law LLC at 205-335-2640. Get Relief Get Results.