Daniel v. State
86 So. 3d 405
Ala. Crim. App.2011Background
- Renard Daniel was convicted in 2003 of capital murder for killing Loretta McCulloch and John Brodie in one course of conduct; the jury recommended death by 10–2, and the circuit court imposed death sentence which this Court affirmed on direct appeal.
- Daniel filed a Rule 32 postconviction petition in February 2006 in Jefferson County; the circuit court initially dismissed, then allowed amendments and eventually dismissed the petition after a 2009 status/dismissal ruling.
- The circuit court’s sentencing order described the double homicide as occurring Sept. 26, 2001, with execution-style killings and corroborated by multiple witnesses, autopsy findings, shoe-impression evidence, and shell casings; this evidence formed the factual backdrop for Daniel’s claims.
- Rule 32 pleading standards require a petitioner to plead a full factual basis of grounds for relief; bare conclusions are insufficient, and a petition may be summarily dismissed if meritless on its face under Rule 32.7(d) when no evidentiary hearing is required.
- No evidentiary hearing was held; the court explained that findings of fact are not required on a summary dismissal, and various claims were rejected for lack of specificity or procedural bar, leading to affirmance of the dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the circuit court erred by not making factual findings on each claim without an evidentiary hearing | Daniel contends the court must provide written findings for each issue | Court need not make specific findings absent an evidentiary hearing | No, findings were not required after summary dismissal |
| Whether Daniel’s ineffective-assistance claims were procedurally barred | Claims could have been raised earlier or on direct appeal | Raised claims were barred by Rule 32.2(a)(3)-(5) and Rule 32.6(b) for lack of specificity | Yes, the court properly barred and dismissed the claims on procedural grounds |
| Whether Daniel pled full facts to support ineffective-assistance claims at the pleading stage | Pleading stage requires adequate notice of claims | Full-fact pleading required; many claims lacked specificity | Yes, many claims were properly dismissed for failure to plead with specificity under Rule 32.6(b) and/or Rule 32.7(d)Colloquially summarized |
| Whether Rompilla/Atkins-type claims were properly rejected for lack of pleading | Defendant failed to plead systemic evidence of retardation or Rompilla-type investigation | No material facts pleaded; Rompilla and Flynn-effect discussions do not prove entitlement | Yes, Rompilla and Atkins-related claims were properly rejected for lack of pleading and evidence |
Key Cases Cited
- Hyde v. State, 950 So.2d 344 (Ala.Crim.App.2006) (full-fact pleading required for Rule 32.6(b))
- Bracknell v. State, 883 So.2d 724 (Ala.Crim.App.2003) (heavy pleading burden; specificity required)
- Ex parte Boatwright, 471 So.2d 1257 (Ala.1985) (meritorious petition requires grounds with facts)
- Rompilla v. Beard, 545 U.S. 374 (U.S. 2005) (penalty-phase counsel must investigate prior convictions when used for sentencing)
- Williams v. Taylor, 529 U.S. 362 (U.S. 2000) (detailed mitigation investigation required in capital cases)
- Davis v. State, 44 So.3d 1118 (Ala.Crim.App.2009) (impeachment strategy and witness credibility considerations)