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Wiggins v. State
193 So. 3d 765
Ala. Crim. App.
2014
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Background

  • Wiggins was convicted of capital murder during a robbery and of robbery; the circuit court imposed death for capital murder and life imprisonment for robbery; the State's evidence included Cavins's murder and Beasley’s robbery, with forensic links to McGinnis's gun and Wiggins's blood/DNA found on clothing.
  • Beasley and Cavins's deaths were linked to the shop where they worked; Cavins suffered multiple gunshot wounds, including to the chest and ear; McGinnis's rifle was involved and linked to the shootings.
  • Wiggins testified that he drank heavily and used drugs; he admitted participating in the events and that he shot Cavins, though he claimed limited memory and intoxication.
  • Defense sought to accept a plea offer for life without parole; the court set a deadline for accepting the deal, which was not accepted by Wiggins.
  • A 41-month arrest-to-trial delay occurred; Barker v. Wingo factors were applied in plain-error review since the speedy-trial claim was not properly preserved; court found no reversible error.
  • The Court conducted a broad plain-error review across issues after political and evidentiary challenges, ultimately affirming the death sentence and related convictions.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Speedy-trial violation Wiggins argues denial of speedy trial. Wiggins asserts excessive delay harmed him. No reversible error; delay deemed presumptively prejudicial but not prejudicial enough under Barker factors.
Plea offer deadline and acceptance Wiggins contends court imposed improper deadline denying plea. Wiggins argues deadline was improper and coerced trial path. Court did not abuse discretion; plea deadline valid and no constitutional violation.
Suppression of statement as involuntary Statement allegedly coerced due to intoxication and fatigue. Statement was involuntary and should have been suppressed. No error; statement voluntary, properly admitted; harmless if any error.
Batson challenge to jury strikes Prosecutor struck Black jurors; claim of racial discrimination. Strikes were race-neutral and not pretextual given differences among jurors. No reversible Batson error; trial court’s ruling not clearly erroneous.
Prosecutorial misconduct and evidence at guilt phase Prosecutor made improper or prejudicial remarks (closing, cross-exam, etc.). Arguments linked to evidence or opened doors; defense not prejudiced. No plain error; cumulative impact not enough to overturn.

Key Cases Cited

  • Ex parte Woodall, 730 So.2d 652 (Ala. 1998) (plain-error review in capital cases; dual-capital/noncapital conviction treatment)
  • Santobello v. New York, 404 U.S. 257 (1971) (trial court's independent judgment in plea bargains; court may reject offers)
  • Ex parte Bryant, 951 So.2d 724 (Ala. 2002) (plain-error standard in weighing aggravators/mitigators; death penalty guidance)
  • Ex parte Belisle, 11 So.3d 323 (Ala. 2008) (lethal injection protocol upheld; method not unconstitutional)
  • Waldrop v. Waldrop, 859 So.2d 1181 (Ala. 2002) ( Ring-Apprendi framework in Alabama context)
Read the full case

Case Details

Case Name: Wiggins v. State
Court Name: Court of Criminal Appeals of Alabama
Date Published: May 2, 2014
Citation: 193 So. 3d 765
Docket Number: CR-08-1165
Court Abbreviation: Ala. Crim. App.