The Alabama Court of Criminal Appeals today reversed Montez Spradley’s conviction and death sentence because the bulk of the State’s evidence against him was improperly admitted, resulting in a “miscarriage of justice.”
The State’s theory at trial was that Montez Spradley murdered Marlene Jason during a robbery, took her credit card, and used the card to purchase gasoline for people in exchange for cash.
It introduced testimony from police investigators about the times and places where the credit card had been used; police testimony that a man told them someone offered to use a credit card to fill his tank with gas in exchange for cash; and surveillance footage showing someone who purportedly resembled Mr. Spradley using a credit card at a gas station.
The video recordings were the only demonstrative evidence linking Mr. Spradley to the use of the credit card, but the State failed to show that they were accurately recorded and preserved. The appeals court held they were improperly admitted.
The court also held that the police testimony was inadmissible hearsay because it was not based on personal, firsthand knowledge. It was plain error to admit this illegal hearsay evidence because it “had ‘an unfair prejudicial impact on the jury’s deliberations.'”
The State also committed plain error when it introduced testimony from a witness that a third person threatened him not to testify against Mr. Spradley because the State failed to link Mr. Spradley to the threat, in violation of longstanding Alabama law. This evidence was highly prejudicial because it “most likely left the jury with the understanding that Spradley was a dangerous person of bad character, who could authorize a threat from jail.”
Finally, the State improperly introduced evidence that Mr. Spradley had been in jail for violating probation. This “bad character” evidence would have had an “almost irreversible impact upon the minds of the jurors,” the court held, and therefore it was improperly admitted.
The appeals court considered all of these errors together and concluded that, because the State’s case consisted almost entirely of illegal and improper evidence, Mr. Spradley is entitled to a new trial.