CALL 205.538.3340

The Law Office of J.D. Lloyd Logo Because There’s Hope After the Trial


After The Trial Blog

The After The Trial blog presents insights on ongoing and recent trials around the state of Alabama, including weekly criminal law round-ups.

Court of Criminal Appeals Decisions - April 2018

J.D. Lloyd - Friday, April 27, 2018

 Pruitt v. State 16-0956



Pruitt pleaded guilty to two counts of committing a sex act with a student, violations of § 13A-6-81, and two counts of distributing obscene material to a minor, violations of § 13A-12-200.5. These offenses involved 3 students Pruitt formerly taught. Pruitt was a teacher in the Blount County School system. She taught at the Locust Fork High School during the 2012-13 and 2013-14 school years. She taught the three students during this time. Beginning in the 2014-15 school year, Pruitt was transferred to Appalachian High School. During October 2014, she sent Student #1 nude Snapchat pictures, had deviate sexual intercourse with Student #2, and had sexual intercourse with Student #3. For all intents and purposes, the acts were consensual. These facts were stipulated by both sides. Prior to pleading guilty, Pruitt, relying on Lawrence v. Texas, argued that the statutes and charges were unconstitutional as applied to her. AFFIRMED The Court of Criminal Appeals rejected the Lawrence-based argument on the grounds that Lawrence explicitly held that the decision didn’t apply to conduct involving minors. Further, the Court concluded that the State has a legitimate state interest in “prohibiting intimate contact between a teacher and a student.” The Court likewise rejected Pruitt’s “consent” defense since the statute expressly says “consent is not a defense.” Finally, the Court held that the fact that Pruitt did not teach at the same school as the students did not entitle her to relief. The Court also rejected an argument that her violation for unlawful distribution of obscene material to a minor didn’t violate her right to Equal Protection to be free from State intervention in a private relationship with a consulting person. The Court ruled against this argument based on the student being a minor (per § 13A-12-200.1) and previous holdings that the State doesn’t violate Equal Protection concerns by prohibiting sexual contact with minors.
Towles v. State CR-15-0699
Towles was convicted of capital murder pursuant to §13A-5-40(a)(15) for killing his girlfriend’s son by hitting him on the buttocks with a piece of lumber. This appealed stemmed from a re-trial after the Court of Criminal Appeals reversed his capital murder conviction and death sentence years back. In the interim, Towles’ girlfriend pleaded guilty for failing to protect her son from Towles. The girlfriend didn’t testify at trial. Towles’ defense was that she caused the death and then blackmailed him to help her cover up the child’s death. However, the State impeached Towles by discussing how she had pleaded guilty for failing to protect her son from Towles. REVERSED The Court concluded that the introduction of the girlfriend’s conviction into evidence was improper evidence of Towles’ guilt. The Court also concluded that the trial court’s instruction that “knowledge of the probability of death or great bodily harm is sufficient to constitute murder” impermissibly lessened the State’s burden and undermined the defense’s argument that the killing was, at most, unintentional. Mr. Towles will now go back for his third trial.


Betton v. State CR-15-1501
Betton was a juvenile capital defendant seeking re-sentencing under Miller v. Alabama. Here, the circuit court re-sentenced him to LWOP without considering the factors the Alabama Supreme Court announced in Ex parte Henderson. REMANDED The Court held that remand was necessary for the circuit court to enter specific findings under Ex parte Henderson.
Battles v. State CR-17-0044
In a prosecution for unlawful possession of a pistol by a forbidden person pursuant to § 13A-11-72(a), Battles waived counsel and represented himself at trial. However, throughout, Battles complained that he didn’t understand the charges against him and complained that he didn’t have the resources necessary to defend his case. REVERSED The Court concluded that while Battles knowingly waived his right to represent himself at trial, the circuit court failed to the factors a court must discuss with a defendant pursuant to Fitzpatrick v. Wainwright, 800 F. 2d 1057 (11th Cir. 1986) and Tomlin v. State, 601 So. 2d 124 (Ala. 1991). Additionally, the court failed to tell Battles he could withdraw the waiver at any time.



If you or someone you know has been convicted of wrongful criminal charges, there is hope after the trial. Contact us today by clicking HERE.



Recent Posts


Jefferson County Alabama eugene lee jones v state alabama criminal law roundup christmas shooting ex parte briseno eric sterling keith v state apprendi v new jersey brendan dassey SCOTUS, Donald Trump, mulga alabama fairfield alabama, breaking and entering midazolam assault netflix texas operation bullseye bernard v north dakota birmingham alabama Malone v State kenneth eugene billups greene county alabama criminal justice reform, crime of passion US Supreme Court Update street racing state of alabama florence alabama benjamin todd acton alfonso morris birchfield v north dakota Glaze v State tarrant alabama narcotics investigation abandonment trussville alabama morris alabama brookside alabama Mike Hubbard mike gilotti alabama supreme court burglary adger alabama battles v state mountain brook alabama Ingmire v State Sardis Alabama baldwin county alabama mcwilliams v dunn adnan syed, fraud madison alabama maryland court of special appeals dekalb county alabama terell corey mcmullin forced isolation drug crimes gun control shooting death Stephen Breyer road rage sexual assault alabama law enforcement agency concealed carry cherokee county alabama aiding and abetting constitutional law, hoover alabama cullman alabama shelby county russell calhoun lethal injection pinson alabama albertville alabama department of justice, drug activity implied consent Guy Terrell Junior Rule 32 homicide rate Lucky D Arcade calhoun county alabama stoves v state utah supreme court fake kidnapping, south carolina baltimore city circuit court campbell v state rainbow city alabama boaz alabama attempted murder moore v texas heflin alabama dora alabama Adamsville alabama sarah koenig fultondale alabama Alonzo Ephraim unlawful manufacturing pelham alabama hanceville alabama sixth amendment armed robbery brendan dassey, steve avery, making a murderer, scotus, netflix ake v oklahoma illegal gun carry bailey v us sentencing law and policy blog summaries murder car accident capital punishment montgomery alabama abuse domestic violence gun rights animal cruelty drug seizure operation crackdown criminal mischief church robberies homicide kimberly alabama Eutaw Alabama Justice Sotomayor Joshua Reese huntsville alabama Gardendale Alabama death penalty moving violations state of arizona arson Benn v State Marengo County Alabama negligent homicide criminal justice marion county blountsville alabama endangerment of a child theft lethal injection drugs William Pryor gadsden alabama jerry bohannon court systems, Etowah County Alabama, bessemer alabama springville alabama the mannequin challenge ferguson missouri OJ Simpson Made in America christian guitierez minor offenses Shonda Walker, warrantless blood draws drug busts economic growth oneonta alabama illegal gambling prostitution sting court of criminal appeals towles v state npr executions habeas corpus relief shooting nicholas hawkins steve avery court of criminal appeal releases john earle redfearn IV v state huntsville Kareem Dacar Gaymon eighth amendment, Dylann Roof alabama brady v maryland abduction dothan alabama West Alabama felony assaults peyton pruitt tuscaloosa alabama anniston alabama, § 13A-3-23 beylund v north dakota fraudulent checks aziz sayyed brian fredick lucas self defense drug trafficking, robberies public assistance fraud morgan county alabama CCA update decatur alabama serial identity theft Pleasant Grove Alabama hoax destructive devices utah v strieff department of justice lauderdale county alabama judicial override clarence thomas pell city alabama home repair fraud bomb threat heritage christian university Hillary Clinton, Briarwood Presbyterian Church kidnapping OJ Simpson lamar county drug possession, Xavier Beasley Wesley Adam Whitworth 28 U.S.C. § 2254 making a murderer blount county alabama hall v florida social media banville v state drug smuggling hurst mandamus Alabaster alabama betton v state embezzlement mount olive alabama debit card skimming scams strickland v washington Woods v State Samuel Alito limestone county alabama LWOP eleventh circuit ruling avondale alabama capital offenses New York Times foley alabama talladega superspeedway Fentanyl death penalty, mobile alabama Tracie Todd asia mcclain fort payne alabama mccalla alabama editorial sheffield v state second amendment constitutional violations hurst v florida parole edwards v arizona levins v state Thomas Hardiman Kay Ivey smith v state warrior alabama Walker County Alabama Neil Gorsuch Tommy Arthur st clair county alabama stanley brent chapman Easter § 13A-3-23(d) immunity hearing 2016 election, pruitt v state capital murder debtor prison underage drinking nathan woods ring v arizona shoplifting legende v state fourth amendment theft of property scotus domestic abuse



These recoveries and testimonials are not an indication of future results. Every case is different, and regardless of what friends, family, or other individuals may say about what a case is worth, each case must be evaluated on its own facts and circumstances as they apply to the law. The valuation of a case depends on the facts, the injuries, the jurisdiction, the venue, the witnesses, the parties, and the testimony, among  other factors. Furthermore, no representation is made that the quality of the legal services to be performed is greater than the quality of legal services performed by other lawyers.

Get Free Legal Advice  Contact us for a complimentary legal consultation

I am interested in scheduling a free legal consultation and receiving additional information.

Submitting Form...

The server encountered an error.

Thank you, your  entry has been  received.

© 2017 The Law Office of J.D. Lloyd, LLC. All Rights Reserved. |


As required by Rule 7.2(e), Alabama Rules of Professional Conduct, no representation is made that the quality of the legal services to be performed is greater than the quality of legal services performed by other lawyers.