Bruce Lanier Austin v. State of Alabama

Court of Criminal Appeals of Alabama·Decided August 21, 2026·No. CR-2025-0978·Published

Opinion

Rel: August 21, 2026

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is published in Southern Reporter.

Alabama Court of Criminal Appeals OCTOBER TERM, 2025-2026

CR-2025-0978

Bruce Lanier Austin

v.

State of Alabama

Appeal from Jefferson Circuit Court (CC-23-2208, CC-23-2209, and CC-23-2210)

WINDOM, Presiding Judge.

Bruce Lanier Austin appeals his convictions for murder made capital because he committed the murder with the use of a deadly weapon while the victim was inside a vehicle, see § 13A-5-40(a)(17), Ala. Code 1975; for first-degree assault, see § 13A-6-20(a)(1), Ala. Code 1975; and

for discharging a firearm into an occupied vehicle, see § 13A-11-61, Ala. Code 1975. Austin was sentenced to life in prison without the possibility of parole for his capital-murder conviction, to 20 years in prison for his assault conviction, and to 20 years in prison for his discharging-a- firearm-into-an-occupied-vehicle conviction. The sentences were ordered to be served concurrently.

On the morning of November 16, 2022, Wallace Franklin heard several gunshots as he ate breakfast. Franklin, who lived near the intersection of 80th Street and 5th Avenue in Birmingham, moved to a monitor that displayed feeds from various security cameras he had installed around his house. Franklin saw a small, gray vehicle drive by, followed by a red sport-utility vehicle ("SUV"). The red SUV veered off the road and struck a power pole. Finally, Franklin saw a black male, dressed in a red and black jumpsuit and armed with an AK-47 rifle, walking down the street from the direction of a nearby apartment building.

Walter Cook was driving the gray vehicle captured by Franklin's security cameras. Cook was driving down 80th Street that morning when he heard a gunshot coming from the direction of a nearby apartment

building. In the rearview mirror, he saw a red SUV veer off the road, and, from his side mirror, he saw a black male wearing a red jumpsuit and holding a rifle. Cook heard more gunshots and sped away before calling emergency 911.

Edker Finton, who lived on 80th Street, described a scene similar to Franklin and Cook. From his bedroom he heard a gunshot. Finton went to the kitchen window, from which he saw a red SUV crash into a power pole and a black male in a red jacket standing in the street firing a long gun into the air at a 45-degree angle. Finton heard more gunshots as he took cover. Finton saw no other individuals outside during the shooting.

Around that time, Austin called his girlfriend, Valerie Garrison, asking her to pick him up from his mother's apartment, which was located near the scene of the shooting. Garrison, who lived nearby, heard gunshots as she walked out of her house. As Garrison approached the intersection of 80th Street and 5th Avenue in her black Chrysler 200 vehicle, she saw Austin walking toward her. Austin was wearing a red, black, and white jumpsuit. He got into her vehicle, and they left.

Officer Johnathan Robbins of the Birmingham Police Department was the first to respond to the shooting. Off. Robbins saw only one bullet defect to the red SUV -- in the front passenger window -- but the damage inside the SUV was catastrophic. The bullet had struck 14-year-old Moriah Quib-Marquez in the head, killing her instantly, before striking Rosa Quib-Chub, her mother, in the head, leaving her permanently disabled. Off. Robbins was able to open the rear passenger door, allowing Marta Quib-Chub, Rosa's sister-in-law, and several children to escape the crashed SUV.

Justin Blair, a crime-scene technician, observed a bullet strike in the passenger-side window of the red SUV, numerous 7.62x39 mm shell casings along 80th Street, a live 7.62x39 mm round on the sidewalk at 526 80th Street, a 9 mm casing in the roadway, and additional 7.62x39 mm casings and a projectile at 79th Street and 5th Avenue. In total, 23 shell casings were discovered at the scene.

The investigation into the shooting quickly turned to Garrison's home and a search for her vehicle. Around 3:00 p.m. that same day, Austin was found with Garrison's vehicle and detained. A search warrant was executed on Garrison's house, which yielded a 7.62x39 mm

shell casing from the roadway in front of Garrison's house. An unfired 7.62x39 mm round was discovered in Garrison's vehicle on the front passenger floorboard.

Forensic testing showed that all the fired 7.62x39 mm casings had been fired from a single firearm and that the two unfired 7.62x39mm rounds found at the scene, which contained light firing-pin indentations, were also struck by that same firearm's firing pin. Testing further showed that the shell casing found in the roadway in front of Garrison's home had been fired from the same firearm used at the scene of the shooting and that the unfired round collected from the front passenger floorboard of Garrison's vehicle contained firing-pin indentations from that same firearm. A bullet fragment found inside the red SUV was consistent with a 7.62x39 mm bullet jacket.

At trial, Austin testified that he had been in conflict with Torrence Craig because Craig had been selling drugs near the apartment of Austin's mother. Austin confronted Craig, telling him to sell drugs somewhere else. According to Austin, he felt threatened by Craig because Craig, in the days leading up to the shooting, had been driving by his mother's apartment. On the morning of November 16, Austin called

emergency 911 to report that he was being threatened. Austin left his mother's apartment that morning armed with a rifle, which he claimed was for protection. Austin testified that, as he walked down the street, he saw three vehicles approach the area, and then heard gunshots. Austin stated that his rifle was loaded with only one round; Austin admitted to firing that round but stated that he did not fire at the red SUV and that the red SUV had struck the power pole before he fired his rifle. Austin admitted that he was the individual walking down the street in Franklin's surveillance video and that he got into Garrison's vehicle. He testified that he did not realize that anyone had been shot.

On appeal, Austin argues: 1) that the sufficiency and weight of the evidence do not establish that he committed the offenses; 2) that the circuit court erred in admitting highly prejudicial photographs into evidence; 3) that the circuit court erred in denying his motion to suppress his custodial statement; 4) that the circuit court erred in allowing improper victim-impact testimony at trial; and 5) that the cumulative effect of the errors deprived him of a fair trial.

I.

Austin contends that the evidence was insufficient to sustain his convictions. Specifically, Austin argues that the State failed to prove that he had the intent to kill or to cause serious physical injury to the occupants of the red SUV or that he was the individual responsible for shooting into that occupied vehicle. Austin claims that, even if he fired the shot that killed Moriah and injured Rosa, the evidence, at most, shows that he acted recklessly.

Concerning the standards governing this Court's review of the sufficiency of the evidence, this Court has held:

"In deciding whether there is sufficient evidence to support the verdict of the jury and the judgment of the trial court, the evidence must be reviewed in the light most favorable to the prosecution. Cumbo v. State, 368 So. 2d 871 (Ala. Cr. App. 1978), cert. denied, 368 So. 2d 877 (Ala. 1979).

Conflicting evidence presents a jury question not subject to review on appeal, provided the state's evidence establishes a prima facie case. Gunn v. State, 387 So. 2d 280 (Ala. Cr.

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