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Stowes v. State

Citations: 513 So. 2d 86; 1987 Ala. Crim. App. LEXIS 4674Docket: 5 Div. 146

Court: Court of Criminal Appeals of Alabama; April 28, 1987; Alabama; State Appellate Court

Narrative Opinion Summary

In this case, the appellant was convicted of murder and sentenced to 20 years in prison following a vehicular accident that resulted in the deaths of two individuals. The primary legal issue concerned the appellant's alleged intoxication, with a blood alcohol content of 0.27 percent being a crucial piece of evidence. During the trial, various witnesses testified regarding the circumstances of the accident and the appellant's state, including the presence of alcohol. The trial court instructed the jury on the presumption of intoxication based on blood alcohol levels, but failed to emphasize the rebuttable nature of this presumption, as established under Alabama law. The defense objected, citing precedents that require clarity in jury instructions concerning such presumptions. The appellate court found this omission to be a significant error, as it potentially affected the jury's evaluation of the evidence. Consequently, the court reversed the conviction and remanded the case for a new trial, underscoring the necessity for precise jury guidance on legal presumptions and their implications in determining criminal liability.

Legal Issues Addressed

Jury Instructions and Presumptions

Application: The trial court's instructions failed to adequately clarify the rebuttable nature of the intoxication presumption, potentially infringing on the jury's role.

Reasoning: The trial court's instructions failed to clarify the rebuttable nature of the intoxication presumption, potentially infringing on the jury's role.

Presumption of Intoxication under Alabama Law

Application: The court discussed the statutory presumption of intoxication arising from a blood alcohol level of 0.10 percent or more and its rebuttable nature.

Reasoning: According to the Alabama Chemical Test for Intoxication Act, a blood alcohol level of 0.10 percent or more raises a presumption of intoxication, but a jury is not mandated to conclude intoxication based solely on this evidence.

Reversible Error in Jury Instructions

Application: The appellate court found reversible error due to the trial court's failure to properly instruct the jury on the rebuttable nature of the statutory presumption of intoxication.

Reasoning: The court found that the trial court's failure to clarify this rebuttable presumption to the jury was highly prejudicial and constituted reversible error.