State v. Alston
Annotate this CaseDefendants were indicted for aggravated robbery, aggravated burglary, and especially aggravated kidnapping. A jury convicted Defendants of all charges. The trial court set aside the guilty verdicts for especially aggravated kidnapping and aggravated burglary, concluding that these convictions, in conjunction with the aggravated robbery convictions, violated due process principles. The Court of Criminal Appeals reversed and reinstated the verdicts, finding that separate convictions for each of the offenses did not violate principles of due process or double jeopardy. The Supreme Court remanded to the intermediate appellate court for consideration in light of the Court’s holding in State v. Cecil, which applied the requirement of a jury instruction pursuant to State v. White to cases already in the appellate process on the date White was issued. On remand, the Court of Criminal Appeals reached the same result. The Supreme Court affirmed, holding (1) a kidnapping charge accompanied by an aggravated burglary charge does not, standing alone, warrant a White jury instruction; and (2) the trial court erred by not instructing the jury pursuant to the requirements of White with regard to the kidnapping charge as accompanied by the aggravated robbery charge, but the error was harmless.
Court Description: Authoring Judge: Chief Justice Sharon G. Lee
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