Jonathan Fitzgerald Lockett v. State of Alabama (Appeal from Jefferson Circuit Court:CC-21-347, CC-21-377, CC-21-378, CC-21-1004, CC-21-1005, CC-21-1006, CC-21-1331, CC-21-1332, CC-21-1466, CC-21-1467, and CC-21-1468).

CourtCourt of Criminal Appeals of Alabama
DecidedAugust 22, 2025
DocketCR-2024-0103
StatusPublished

This text of Jonathan Fitzgerald Lockett v. State of Alabama (Appeal from Jefferson Circuit Court:CC-21-347, CC-21-377, CC-21-378, CC-21-1004, CC-21-1005, CC-21-1006, CC-21-1331, CC-21-1332, CC-21-1466, CC-21-1467, and CC-21-1468). (Jonathan Fitzgerald Lockett v. State of Alabama (Appeal from Jefferson Circuit Court:CC-21-347, CC-21-377, CC-21-378, CC-21-1004, CC-21-1005, CC-21-1006, CC-21-1331, CC-21-1332, CC-21-1466, CC-21-1467, and CC-21-1468).) is published on Counsel Stack Legal Research, covering Court of Criminal Appeals of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jonathan Fitzgerald Lockett v. State of Alabama (Appeal from Jefferson Circuit Court:CC-21-347, CC-21-377, CC-21-378, CC-21-1004, CC-21-1005, CC-21-1006, CC-21-1331, CC-21-1332, CC-21-1466, CC-21-1467, and CC-21-1468)., (Ala. Ct. App. 2025).

Opinion

Rel: August 22, 2025

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, 2024-2025 _________________________

CR-2024-0103 _________________________

Jonathan Fitzgerald Lockett

v.

State of Alabama

Appeal from Jefferson Circuit Court (CC-21-347, CC-21-377, CC-21-378, CC-21-1004, CC-21-1005, CC-21- 1006, CC-21-1331, CC-21-1332, CC-21-1466, CC-21-1467, and CC-21- 1468)

ANDERSON, Judge. CR-2024-0103

Jonathan Fitzgerald Lockett 1 appeals his convictions for first-

degree rape, first-degree sodomy, sexual torture, first-degree robbery,

and second-degree theft of property. On appeal, Lockett asserts 2

arguments: (1) that the Jefferson Circuit Court abused its discretion

when it consolidated 12 charges against him that were brought in

separate indictments and related to 5 different victims and (2) that the

circuit court abused its discretion when it allowed the State to show the

jury footage depicting his sodomizing an unidentified victim, for which

he was not charged. For the reasons set forth in this opinion, we find no

merit to either claim.

However, even though Lockett does not challenge his two

convictions for first-degree robbery of C.P., for the reasons set forth below

we reverse and remand as to case number CC-21-347. Because Lockett's

convictions for first-degree robbery were based on different methods of

proving the same criminal act of robbery committed against the same

victim, those convictions violate double-jeopardy principles. In Ex parte

1The indictments returned against Lockett indicated multiple aliases, including "Master Antonio Lockett," "Master Antonio Jay Ramsey Lockett," "Jonathan Lockett," "John Lockett," and "Master Lockett." (C. 104-07.) 2 CR-2024-0103

Rice, 766 So. 2d 143, 152 (Ala. 1999), the court found that it was not "an

acceptable option to merely vacate one … conviction[] and its

corresponding sentence" because such an action by the appellate court

"would have the effect, albeit unintended, of nullifying a part of the jury's

verdict." On remand, therefore, the circuit court must enter a new order,

one that adjudges the defendant guilty of the single offense first-degree

robbery as to C.P. and "sentences him for that single offense." Id. at 152-

53.

Facts and Procedural History A Jefferson County grand jury indicted Lockett and charged him

with several sex and theft crimes committed against different victims:

• In case number CC-21-347, two counts of first-degree robbery as to victim C.P.;

• In case number CC-21-377, one count of first-degree rape as to victim C.P.;

• In case number CC-21-378, one count of first-degree sodomy as to victim C.P.;

• In case number CC-21-1004, one count of sexual torture as to victim S.K.;

• In case number CC-21-1005, one count of first-degree robbery as to victim S.K.;

3 CR-2024-0103

• In case number CC-21-1006, one count of first-degree sodomy as to victim S.K.;

• In case number CC-21-1331, one count of first-degree sodomy as to victim L.S.;

• In case number CC-21-1332, one count of second-degree theft as to victim L.S.;

• In case number CC-21-1466, one count of first-degree sodomy as to victim J.W.;

• In case number CC-21-1467, one count of first-degree robbery as to victim J.W.;2 and

• In case number CC-21-1468, one count of first-degree sodomy as to victim K.R.

(C. 1177-88.) Before trial, the State moved to consolidate the charges

against Lockett, and the circuit court granted that motion over Lockett's

objection. (C. 1609-10; R. 21.)

The State's evidence showed that, in a nearly one-year period

spanning from late 2019 to late 2020, Lockett committed numerous

sexual assaults and thefts in areas close to his two Birmingham

residences. The first sexual assault and theft occurred in October 2019

and was committed against L.S., who worked as a prostitute in

2Lockett was also charged with first-degree rape against J.W. in

case number CC-21-1329, but the State voluntarily dismissed that charge during its case-in-chief. (R. 543.) 4 CR-2024-0103

Birmingham. (R. 103-05.) L.S. posted online advertisements seeking

clients, and Lockett responded to one of them. (R. 105-06.) Lockett told

L.S. to meet him at an address on First Avenue South. (R. 111-12.) When

L.S. arrived, she realized the address was for a house near a church. (R.

112-13.) She carried a purse containing her cellular telephone and a

purple and black pistol. (R. 116.) Lockett eventually met L.S. at her car,

gave her some money, and led her to a laundry room located at the rear

of the house. (R. 113-16, 118-19.)

Although Lockett was initially friendly, when he and L.S. entered

the laundry room Lockett pushed her over, gripped her hair, and said,

"[b]itch, you know what we came here to do." (R. 118-19.) Lockett then

grabbed L.S.'s pistol, took the money he gave her, and forced her to

engage in nonconsensual vaginal sex and anal penetration with his

fingers.3 (R. 119-21.) According to L.S., she and Lockett discussed

engaging in oral and vaginal sex, but she never agreed to engage in anal

sex. (R. 129-30, 134.) The sexual contact was not consensual, and it did

3Additional evidence supported a finding that Lockett also penetrated L.S. with his penis. Specifically, semen matching Lockett's DNA was found in the rectal swab from L.S.'s sexual-assault exam, and Lockett himself testified that he anally penetrated her with his penis. (R. 204-05, 314-15, 561.) 5 CR-2024-0103

not occur until after Lockett took L.S.'s pistol. (R. 134-35.) Lockett also

recorded the assault, and the footage depicted L.S. saying "oh, God,

please no." (R. 121-23.)

Lockett eventually stopped and left, but he took the pistol with him.

(R. 121.) L.S. left the scene of the attack and drove to a nearby pawn shop

and called emergency 911. (R. 123.) She then went to a local crisis center

where a sexual-assault examination was performed. (R. 126.) L.S.

reported significant pain in her back and anal area. (R. 174.) The nurse

conducting the examination observed no vaginal injuries, but she

identified an abrasion inside L.S.'s anus. (R. 179-80.) A forensic biologist

with the Alabama Department of Forensic Sciences (the "ADFS")

confirmed the presence of semen on the vaginal, genital, and anal swabs

taken during L.S.'s exam. (R. 204-05.) A later comparison of the semen to

Lockett's DNA sample indicated it was Lockett's semen. (R. 314-15.)

The next victim, C.P., worked as a prostitute in Birmingham in

December 2019. (R. 211-14.) Lockett responded to her online

advertisement, and the two exchanged text messages over multiple days.

(R. 215-16, 220.) They eventually agreed on a price, and Lockett told C.P.

6 CR-2024-0103

to meet him at a different address on First Avenue South.4 (R. 222.) The

address was for a house; when C.P. arrived, she parked in an alley behind

the house, and Lockett led her into the garage. (R.

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Jonathan Fitzgerald Lockett v. State of Alabama (Appeal from Jefferson Circuit Court:CC-21-347, CC-21-377, CC-21-378, CC-21-1004, CC-21-1005, CC-21-1006, CC-21-1331, CC-21-1332, CC-21-1466, CC-21-1467, and CC-21-1468)., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jonathan-fitzgerald-lockett-v-state-of-alabama-appeal-from-jefferson-alacrimapp-2025.