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Jones v. State
Citations: 526 So. 2d 668; 1988 Ala. Crim. App. LEXIS 422; 1988 WL 48405Docket: 3 Div. 807
Court: Court of Criminal Appeals of Alabama; April 26, 1988; Alabama; State Appellate Court
Willie Jones was indicted for two counts of first-degree robbery in Montgomery County, violating Alabama Code § 13A-8-41. After a motion to suppress evidence was denied, he was tried and found guilty on September 1, 1987, receiving a twenty-five-year prison sentence. On February 13, 1987, Deputy Sheriffs were alerted to an ongoing bank robbery at Southtrust Bank and observed a suspicious black male fleeing from an apartment complex. Although they initially lost sight of him, they later spotted him again, leading to a traffic stop after he ran a stop sign. Upon stopping, they discovered Jerome Gary, the actual bank robber, hiding in the car. The officers, believing Jones matched a composite sketch of a suspect, began questioning him. His nervous behavior raised suspicion. After Jones was arrested for disorderly conduct, officers searched his vehicle, discovering money from the Southtrust Bank robbery in the trunk. Jones's motion to suppress this evidence, claiming it resulted from an unlawful search, was denied; the court found sufficient probable cause justified the search. Probable cause and exigent circumstances create an exception to the requirement for a warrant in searches, as established in various Alabama case law. There is no uniform test for determining probable cause; it must be assessed based on the specific facts of each case. Probable cause involves factual and practical considerations rather than technicalities, relying on what a reasonable person would deem sufficient to believe a crime has occurred or is occurring. In a particular instance, deputies were alerted to a robbery in progress and observed a suspect (the appellant) fleeing in a vehicle. After identifying the suspect through a composite drawing related to a prior robbery, the deputies continued their pursuit. The appellant's running of a red light provided a lawful basis for a traffic stop, constituting a "Terry Stop," which allows officers to investigate further based on reasonable suspicion. Officer Simmons, upon arrival, was informed that the appellant was a suspect in a bank robbery, leading him to assume the appellant was under arrest and to request the keys to impound the vehicle. The appellant was arrested for disorderly conduct after becoming belligerent. Although individual facts may not indicate probable cause, the overall circumstances suggested reasonable suspicion linking the appellant to the Southtrust Bank robbery. He was seen running towards his vehicle near the bank shortly after a robbery report, resembling a composite sketch of a robber from a previous heist. Although the officers were unaware of the composite at the time, the appellant's behavior and location raised suspicions. Upon stopping the vehicle, officers discovered Jerome Gary hiding in the back seat; he was identified as the bank robber matching the composite. The appellant displayed nervousness and hostility during questioning, and Gary attempted to flee when the appellant was arrested. Descriptions of the robbery suspect and the appellant's vehicle had been circulated over police radio. The arresting officer believed the appellant matched the composite of a felony suspect. The trial court's decision not to suppress evidence was deemed within its discretion and not clearly erroneous, leading to the affirmation of the case by the Court of Criminal Appeals.