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Ex Parte Woodson
Citations: 578 So. 2d 1049; 1991 Ala. LEXIS 77; 1991 WL 32276Docket: 89-1336
Court: Supreme Court of Alabama; February 14, 1991; Alabama; State Supreme Court
Coleman Woodson was convicted of reckless driving and driving under the influence (DUI) by the City of Selma, with convictions affirmed by the Court of Criminal Appeals. The key issue on certiorari review was whether the City failed to establish a prima facie case due to the non-introduction of the relevant municipal ordinance. Woodson was arrested on March 12, 1987, convicted in the Municipal Court, and subsequently found guilty by a jury in the Dallas Circuit Court on appeal. His penalties included a suspended sentence for reckless driving, a fine of $100, a $25 payment to the Alabama Crime Victims' Compensation Fund, and a 6-month jail sentence with a $2,500 fine for DUI. Woodson contended that the City did not meet its burden of proof because Municipal Ordinance 17-1, which adopted relevant state offenses, was not introduced as evidence. Although it was stipulated during the trial that the City could prosecute under the ordinance without introducing it, Woodson argued that this stipulation did not absolve the City from formally presenting the ordinance in court. Citing precedents, Woodson pointed out that similar cases (Felder v. City of Huntsville and Hanson v. City of Trussville) established that failing to introduce the ordinance resulted in failing to make a case against the defendants. The case ultimately raises questions about the necessity of introducing municipal ordinances in prosecutions based on state law. The Court of Criminal Appeals determined that the City of Selma was required to plead and prove the relevant municipal ordinance to establish a prima facie case against the appellant. The city failed to introduce this necessary ordinance, leading the court to conclude that the appellant's motion for dismissal should have been granted. The ruling drew on precedents, particularly Maxwell v. City of Mobile, which emphasized the necessity of presenting the ordinance to support the prosecution's case. Woodson argued that this failure was a critical issue preserved for appeal, supported by the court's previous rulings that recognized a defendant’s motion to exclude evidence can preserve such issues. The court affirmed that Woodson adequately raised the argument regarding the ordinance's absence, thus preserving the issue for appeal. Consequently, the court reversed the judgment of the Court of Criminal Appeals and remanded the case for further proceedings. The decision included concurring opinions from several justices, while two justices dissented.