Alabama v. MoyersAnnotate this Case
The issue this case presented for the Supreme Court's review centered on the Court of Criminal Appeals' decision ordering the Limestone Circuit Court to set bail for Joel Moyers. Moyers was charged with a capital offense, and an issue arose over whether a defendant so charged was entitled to bail if the State did not intend to seek the death penalty. The State argued that the Court of Criminal Appeals' decision in this matter conflicted with longstanding Alabama case law ("Ex parte Bynum," 312 So. 2d 52 (1975)). Alternatively, the State argued that the Court of Criminal Appeals' decision raised a material question of first impression that required decision by the Supreme Court. Based on the plain meaning of the statutory and constitutional provisions and the development of the case law in this area, the Supreme Court held that a "capital offense" within the meaning of constitutional and statutory provisions relating to bail is an offense that is punishable by death or by life imprisonment without the possibility of parole. Therefore, when a defendant who is charged with a capital offense requests a trial court to set bail, under Ex parte Bynum, the court can deny that request for bail even if the State will not seek the death penalty. However, in order for the trial court to deny a request for bail from a defendant charged with a capital offense, the State must prove the three prerequisites noted in "Ex parte Patel," (879 So. 2d 532 (Ala. 2003)): "'The evidence must be clear and strong, that it would lead a well-guarded and dispassionate judgment to the conclusion that (1) the offense has been committed; (2) the accused is the guilty agent; and (3) he would probably be punished capitally if the law is administered.'" Moreover, Ex parte Patel held that if a defendant has been indicted for a capital offense, that defendant is presumed guilty for purposes of setting bail, and the defendant has the burden to overcome that presumption before he or she is entitled to bail as a matter of right. The Supreme Court reversed the judgment of the Court of Criminal Appeals and remanded this case for further proceedings.