Pruitt v. State

Citation: 272 So. 3d 732Docket: CR–16–0956

Court: Court of Criminal Appeals of Alabama; April 27, 2018; Alabama; State Appellate Court

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Ashley Parkins Pruitt, a former school employee, pleaded guilty under a negotiated plea agreement to two counts of engaging in sexual acts with students under 19 (violating Ala. Code 1975 § 13A-6-81) and two counts of distributing obscene material to a minor (violating Ala. Code 1975 § 13A-12-200.5). The circuit court sentenced her to 15 years for each sexual act conviction, split to include 1 year in jail, 2 years of house arrest, and 3 years of supervised probation, while the obscene material convictions resulted in 1 year in jail (split to 6 months in jail and 3 years probation). All sentences are to run concurrently. Pruitt was also ordered to pay fines totaling $2,500, along with $250 to a victims' compensation fund and court costs.

Pruitt was employed by the Blount County Board of Education as a teacher and coach from 2008 to 2015, primarily at Locust Fork High School during the 2012-2014 school years. The victims, aged 16 to 18, were students at Locust Fork High School, where Pruitt taught. In October 2014, she sent a nude photograph to Victim 1, a 16-year-old, via Snapchat; Victim 1 stated the photos did not harm him, but the State argues that harm is determined by community standards. The statute defines "harmful to minors" based on community standards regarding prurient interest, offensiveness, and lack of serious value. Pruitt also engaged in sexual intercourse with Victim 2 (16) and Victim 3 (18) in October and September 2014, respectively. While the acts were consensual, the State contends that consent is not a valid defense under the relevant statute.

Pruitt filed a motion to dismiss her charges, claiming the statutes she pleaded guilty under were unconstitutional as applied to her situation. After entering her guilty plea, she renewed this motion, asserting her constitutional challenge and preserving her argument regarding the statutes' constitutionality. On appeal, she contends that Alabama Code § 13A-6-81 is unconstitutional in her case, arguing the legislature did not intend it to apply to teachers and students, aged 16 and older, who are not in the same school. She cites the Supreme Court case Lawrence v. Texas to support her claim, asserting that Alabama's age of consent protects her from prosecution for her interactions with students. 

The appellate court reviews statutory interpretations de novo, without a presumption of correctness. A defendant challenging a statute's constitutionality bears the burden of proof. A statute can be found unconstitutional either "as applied" to specific facts or "on its face." Generally, the defendant must demonstrate that the statute operates unconstitutionally concerning their particular circumstances. Statutes are presumed constitutional, and courts must approach constitutional questions with a presumption of validity, sustaining legislative acts unless it is clear beyond reasonable doubt that they violate fundamental law. To overcome this presumption, the challenger must provide evidence of unconstitutionality.

Pruitt pleaded guilty to violating Ala. Code 1975, § 13A-6-81, which criminalizes sexual acts between school employees and students under 19 years of age, irrespective of the student's gender or consent. Pruitt, a teacher, does not dispute her status as a school employee or that the victims were her students. She argues, however, that because the victims were 16 years or older and attended a different school, the application of the statute was unconstitutional. Pruitt cites Lawrence v. Texas, claiming it supports her position as it involved consenting adults. The Supreme Court in Lawrence ruled that a Texas statute criminalizing same-sex conduct violated the Due Process Clause, as it pertained to private, consensual acts between adults. However, the circumstances in Pruitt's case differ significantly; the statute specifically prohibits sexual conduct between a school employee and students under 19. Pruitt engaged in sexual acts with a 16-year-old and an 18-year-old student and sent explicit photographs to another 16-year-old student, all of whom are considered minors under Alabama law. The ruling in Lawrence does not apply to her case, as it does not involve adult consensual conduct free from coercion or exploitation. Additionally, there is a recognized state interest in preventing sexual relationships between teachers and students due to the unique power dynamics and potential for exploitation inherent in such relationships, as affirmed by case law from other jurisdictions.

Teachers are entrusted with significant responsibility and access to students, creating a framework of trust among school districts, parents, and the public. The Connecticut Supreme Court emphasized the importance of this trust, suggesting that the legislature should unequivocally prevent school employees from misusing their access to students for sexual purposes. A Texas statute that prohibits sexual intercourse between teachers and students aligns with legitimate governmental interests, as a sexually charged atmosphere could disrupt students' educational experience. 

Pruitt's argument regarding the victims' ability to consent is countered by Alabama Code 13A-6-81, which states that consent is not a defense. While Pruitt references Alabama Code 30-1-4 to claim that individuals aged 16 and older can make decisions about sexual partners, the court finds no legislative intent in that statute to support such a broad assertion, especially given the explicit prohibition in 13A-6-81 against sexual contact between school employees and students under 19. 

The court interprets 13A-6-81 based on its clear, unambiguous language, which prohibits any sexual acts between school employees and students, regardless of whether they are at the same school. Pruitt, having taught the victims for one to two years at Locust Fork High School, later engaged in sexual acts with students after transferring to Appalachian High School within the same school system. The timeline indicates that within a month of her transfer, she engaged in sexual conduct with one victim and sent inappropriate photographs to another, underscoring the statute's aim to protect students from such abuses of trust.

Pruitt engaged in sexual conduct with student victims shortly after her transfer to a different school, indicating an attempt to evade state laws that criminalize sexual contact between teachers and students within the same school system. The court affirmed that the state's interest in protecting students continues regardless of school transfers, and Pruitt did not prove that the application of 13A-6-81 was unconstitutional in her case.

Additionally, Pruitt challenged her misdemeanor convictions for distributing obscene material to a minor, arguing that 13A-12-200.5 infringed on her Equal Protection Rights. She claimed that the state lacked a legitimate interest in her private relationship with a consenting individual. However, the statute, which prohibits distributing harmful material to minors, is rooted in the need to protect children, as affirmed in Ex parte Woodard. The court noted that laws not based on suspect classifications and not infringing on fundamental rights are evaluated under the 'rational relationship' standard. The state's legitimate interest in safeguarding minors supports the constitutionality of 13A-12-200.5. Consequently, Pruitt's appeal was denied, and the circuit court's judgment was affirmed.