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


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



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.