The Alabama Court of Criminal Appeals held that multiple recent controlled buys supported a residential search warrant and that officers also acted in objective good faith.
The court affirmed. Juvenile-probation revocation determines whether the young person violated conditions of an existing disposition; it is not a prosecution imposing punishment for a new offense. Like adult probation revocation, it therefore does not place the probationer in jeopardy for the alleged conduct and does not prevent a later delinquency adjudication based on that conduct.
The Court of Criminal Appeals affirmed the conviction. Its lengthy opinion rejected Brown’s asserted errors after reviewing the circumstances of the operation, the shooting, the proof of Brown’s knowledge and intent, and the trial court’s challenged rulings. The court concluded that none of the preserved issues required reversal and found no plain error adversely affecting Brown’s substantial rights.
The Court of Criminal Appeals reversed. Although some nonhearsay evidence connected Hatfield to the vehicle or scene, none connected him to the criminal conduct itself. The crucial identification link depended on hearsay. Alabama’s revocation standard is less demanding than proof beyond a reasonable doubt, but a finding still cannot rest solely on hearsay evidence.
The Court of Criminal Appeals affirmed the capital-murder and first-degree-assault convictions and their sentences. It concluded, however, that the conviction for discharging a firearm into an occupied vehicle violated double-jeopardy principles because the proven act underlying that offense was also used to establish the charged form of capital murder.
The Court of Criminal Appeals reversed. The deputy’s account relayed statements made by other people and did not provide nonhearsay proof that Wallace committed domestic violence. Evidence establishing surrounding circumstances or explaining the investigation was not enough unless some admissible evidence connected Wallace to the alleged violation itself.