Martin v. State, 62 So. 3d 1050

Brent E. Martin was indicted on three counts of capital murder; case numbers CC-06-364, CC-06-365, and CC-06-671 charged separate murders and a single-scheme murder count.
A jury convicted Martin on all three counts and, by a 10-2 vote, recommended a death sentence; the trial court imposed death.
The crimes occurred during a hostage-taking incident involving Martin, Alicia Dixon, Nakayla Randolph, Amari, Darryl Carrillo, and Johnnie Randolph III, with Martin threatening, torturing, and ultimately killing two victims after holding several hostages overnight.
Evidence included that the bullet killing Johnnie was from Martin's gun, a bullet from Carrillo possibly from Martin's gun, and a footprint near the bodies matched Martin's shoes; Ogletree aided in committing the offenses.
On appeal, Martin challenged Batson claims about the state's peremptory strikes and later asserted ineffective assistance of counsel for penalty-phase investigations; the court reviewed under plain-error standard as appropriate.
The Court affirmed the capital-murder convictions and the death sentence, finding no reversible plain error in the proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Batson challenge to jury venire strikes	Martin contends the State struck B.B. on racial grounds (pretextual reasons).	State asserts race-neutral, non-pretextual reasons for strikes; trial court accepted them.	No reversible error; reasons race-neutral, not pretextual.
Ineffective assistance of counsel at penalty phase	Counsel failed to adequately investigate and present mitigating evidence; hours and resources insufficient.	Record shows some mitigation; counsel conducted some investigation and presented witnesses; no demonstrated prejudice.	No plain error; cannot show deficient performance or prejudice given record.
Propriety of death sentence after expert-mitigation review	Penalty-phase representation failed to uncover mitigating information; death sentence may be disproportionate.	Four statutory aggravators found; multiple mitigating factors weighed; sentence not disproportionate.	Death sentence affirmed as proportional and supported by the record.

Batson v. Kentucky, 476 U.S. 79 (1986) (discriminatory use of peremptory challenges)
Ex parte Branch, 526 So.2d 609 (Ala. 1987) (race-neutral explanations required in Batson inquiry)
Ex parte Brooks, 695 So.2d 184 (Ala. 1997) (plain-error review standards in capital cases)
United States v. Young, 470 U.S. 1 (1985) (plain-error doctrine standards)
Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance of counsel)