Williams v. State
2012 Ala. Crim. App. LEXIS 44
Ala. Crim. App.2012Background
- Patricia Williams was convicted in 2007 of manufacturing methamphetamine (first degree), trafficking methamphetamine, and unlawful possession of methamphetamine, with life terms for the first two and 15 years for the third.
- This Court affirmed on direct appeal in 2008, and a judgment certificate was issued in 2008.
- Officers found a meth lab in Williams’s shed and methamphetamine in a padlocked mobile-home bedroom, including meth oil on a hot plate and various lab precursors.
- Williams filed a second Rule 32 petition in 2011 arguing actual innocence and lack of jurisdiction due to double jeopardy.
- The circuit court granted summary disposition, dismissing the petition, and Williams appealed challenging the rulings.
- The court held that Williams’s actual-innocence claim is time-barred, but her double-jeopardy claims for trafficking vs possession and for manufacturing vs trafficking were addressed as to relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Actual innocence time-bar | Williams asserts actual innocence. | State argues time-bar under Rule 32.2(c). | Claim time-barred; precluded by Rule 32.2. |
| Double jeopardy: manufacturing vs trafficking | Manufacturing and trafficking violate double jeopardy since based on same evidence. | Blockburger analysis shows distinct elements; not the same offense. | No double jeopardy violation; convictions valid. |
| Double jeopardy: trafficking vs possession | Trafficking and possession are the same offense or included; deserve separate convictions. | Possession and trafficking can be distinct or unit of prosecution varies by facts. | Trafficking and possession constitute same unit of prosecution; possession is a lesser included offense; conviction vacated. |
| Remedy for lesser-included offense | Vacate the lesser-included conviction. | Remedy not at pleading stage; require evidentiary development. | Conviction for possession vacated; remand for relief consistent with rule. |
Key Cases Cited
- Snowden v. State, 968 So.2d 1004 (Ala.Crim.App.2006) (double-jeopardy analysis for same act vs distinct offenses)
- Townsend v. State, 823 So.2d 717 (Ala.Crim.App.2001) (unit-of-prosecution factors for possession/trafficking)
- Ex parte Fletcher, 718 So.2d 1132 (Ala.1998) (possession as lesser included offense in trafficking context)
- Ex parte Hubbard, 562 So.2d 583 (Ala.1989) (possession vs trafficking related analysis)
- Ex parte Darby, 516 So.2d 786 (Ala.1987) (principles on multiple offenses and conviction limits)