112 So. 3d 1108
Ala. Crim. App.2012Background
- Smith appeals denial of postconviction relief from May 7, 1992 capital murder convictions and death sentence.
- Trial occurred after extensive Rule 32 proceedings including a mental-retardation hearing and multiple expert evaluations.
- Judge found Smith not mentally retarded under Atkins criteria and denied relief on remaining claims as precluded or without merit.
- Evidence showed Smith abducted victim at ATM, coerced into trunk, used victim’s debit card, and killed her execution-style; car burned later.
- The circuit court addressed claims of Haldol administration, ineffective assistance of counsel, Batson discrimination, Double Jeopardy/ Ring-Apprendi issues, and execution method; all challenged and affirmed the denial of Rule 32 petition.
- Smith’s appeal challenges mental retardation ruling, alleged coercive drug administration, counsel performance, juror discrimination, and Ring/Apprendi-based sentencing flaws; the order was affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mental retardation claim under Atkins/Perkins | Smith argues he is mentally retarded under Atkins standards | Smith's burden satisfied by preponderance evidence; court erred | No abuse; court properly weighed expert evidence |
| Haldol administration and due process | Haldol compromised Sixth/Fifth Amendment rights and trial fairness | No proof of medication or ineffective assistance; precluded or meritless | Granted/denied relief not warranted; evidence insufficient to show prejudice |
| Ineffective assistance of counsel at penalty phase | Counsel failed to present mitigating/retardation evidence and to handle testing | Counsel acted within reasonable professional judgment; evidence insufficient | No Strickland prejudice; trial counsel not ineffective |
| Batson claims against prosecutor | Prosecutor discriminated in juror strikes | Evidence insufficient to show ineffective assistance or prima facie discrimination | Precluded; no reversible error on Batson grounds |
| Ring/Apprendi sentencing and jury findings | Jury did not determine all sentencing facts; Ring/Apprendi violation | Jury findings on aggravating circumstances sufficient; no error | No Ring/Apprendi violation; Alabama scheme valid |
Key Cases Cited
- Atkins v. Virginia, 536 U.S. 304 (U.S. 2002) (death-rate determination; standards for mentally retarded defendants)
- Ex parte Perkins, 851 So.2d 453 (Ala.2002) (Alabama standard for Atkins claims; use of clinical definitions)
- Ring v. Arizona, 536 U.S. 584 (U.S. 2002) (requirement that jury, not judge, find aggravating factors beyond a reasonable doubt)
- Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000) (requirement that facts increasing penalty beyond statutory maximum be proved to a jury)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong standard for ineffective assistance of counsel)