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