Jones v. Hamm (DEATH PENALTY)

CourtDistrict Court, M.D. Alabama
DecidedAugust 15, 2025
Docket1:21-cv-00362
StatusUnknown

This text of Jones v. Hamm (DEATH PENALTY) (Jones v. Hamm (DEATH PENALTY)) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jones v. Hamm (DEATH PENALTY), (M.D. Ala. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA SOUTHERN DIVISION

ANTONIO DEVOE JONES, ) ) Petitioner, ) ) v. ) CASE NO. 1:21-cv-362-ECM ) [WO] JOHN Q. HAMM, Commissioner, ) Alabama Department of Corrections, ) et al., ) ) Respondents. )

MEMORANDUM OPINION and ORDER

Now pending before the Court is Petitioner Antonio Devoe Jones’ (“Jones”) Verified Petition to Perpetuate Testimony in a Death Penalty Case (doc. 28), which the Respondents oppose. For the reasons that follow, the petition is due to be denied. I. BACKGROUND Jones was convicted of capital murder for the New Years Eve 1999 killing of Ruth Kirkland in Dothan, Alabama. Jones v. State, 987 So. 2d 1156, 1158 (Ala. Crim. App. 2006). The murder was made capital “because it was committed during the course of a burglary in the first degree.” Id. (citing ALA. CODE § 13A-5-40(a)(4)). The jury recommended that Jones be sentenced to death. Id. The trial court accepted the jury’s recommendation and sentenced Jones accordingly. Jones’ conviction and sentence were affirmed on direct appeal. Id. at 1172. Both the Alabama Supreme Court and the United States Supreme Court denied certiorari review. Jones next sought postconviction relief pursuant to Rule 32 of the Alabama Rules of Criminal Procedure. Ultimately, the Circuit Court summarily dismissed his Rule 32

petition without affording an evidentiary hearing. (Doc. 1 at 12, para. 40). The Alabama Court of Criminal Appeals (“ACCA”) dismissed Jones’ appeal on jurisdictional grounds. Jones v. State, 268 So. 3d 584 (Dec. 12, 2017) (Table). The Alabama Supreme Court reversed and remanded. Ex parte Jones, 322 So. 3d 970 (Ala. 2019). On remand, the ACCA affirmed the summary dismissal of the Rule 32 petition. Jones v. State, 322 So. 3d 979 (Ala. Crim. App. 2019). Both the Alabama Supreme Court and the United States

Supreme Court denied certiorari review. Jones filed the instant federal habeas petition in May 2021. II. JONES’ VERIFIED PETITION Jones seeks an order pursuant to Rule 27 of the Federal Rules of Civil Procedure authorizing him to take the deposition of his lone surviving trial attorney, Clark M. Parker.

He asserts that Mr. Parker “has candidly admitted prejudicial mistakes in his understanding of the Alabama law governing the death penalty,” which caused counsel to present a “legally invalid defense” at trial and on appeal. (Doc. 28 at 1). Jones maintains that a “different valid and meritorious defense was available but was not raised at trial.” (Id.). Jones’ verified petition is supported by the affidavit of Mr. Parker, who testifies, in

pertinent part, as follows: in defending against the capital murder charge of murder during the course of a burglary, he “was operating with the misunderstanding that a completed theft from the dwelling was a necessary element for the State to prove that a burglary had occurred”; he believed the lack of direct evidence that anything had been taken from Mrs. Kirkland’s home provided him with “a valid defense to the burglary aggravating factor”; his strategy during trial was “to emphasize the lack of evidence that anything was taken

from the house”; the prosecution argued at trial, and the trial court instructed the jury, that “intent to commit a theft from the dwelling, and not an actual completed theft,” was all that was required to be proved by the State in order to support its capital murder charge; and even after Jones was convicted and sentenced to death, he “continued to argue [on appeal] that the State had failed to prove burglary due to the lack of evidence that anything was taken from the house.” (Doc. 28-1 at 4–5, paras. 9–13). Mr. Parker thus summarizes his

testimony as follows: My belief throughout the trial and appeal was that a completed theft was necessary to establish burglary. I now understand that my belief was in error. This was a mistake on the part of defense counsel, and it was not an intentional strategy on my part to argue something that was contrary to the established law.

(Id. at 5, para. 14). Finally, Mr. Parker addresses his failure to argue that Jones should have been convicted of only felony murder, which, had that defense succeeded, would have rendered Jones ineligible for the death penalty under Alabama law. (Id. at 6, paras. 17–20). Specifically, Mr. Parker testifies that, if he had not misunderstood Alabama law regarding burglary, and if he had a proper understanding of Alabama’s felony murder law, he would have argued the felony murder defense rather than the faulty defense he presented at trial. (Id. at 6, para. 20). III. LEGAL STANDARD Rule 27 contains three provisions addressing actions to perpetuate testimony by

deposition. Rule 27(a) provides that, before a civil action is filed, a “person who wants to perpetuate testimony” about a matter within the purview of a federal court “may file a verified petition in the district court for the district where any expected adverse party resides.” This verified petition “must ask for an order authorizing the petitioner to depose the named persons in order to perpetuate their testimony.” FED. R. CIV. P. 27(a)(1). Further, the verified petition must show, inter alia, that the petitioner “expects to be a party to an

action cognizable in a United States court but cannot presently bring it or cause it to be brought,” “the facts that the petitioner wants to establish by the proposed testimony and the reasons to perpetuate it,” and the name and “expected substance of the testimony of each deponent.” FED. R. CIV. P. 27(a)(1)(A)–(E). Rule 27(b), on the other hand, provides for depositions to perpetuate testimony pending appeal. Specifically, where an appeal has

been taken from a judgment of the district court, or may still be taken, a party may move in the district court to depose a witness to perpetuate the witness’s testimony “for use in the event of further proceedings in that court.” FED. R. CIV. P. 27(b)(1). Finally, Rule 27(c), under the heading “Perpetuation by Action,” provides simply that “[t]his rule does not limit a court’s power to entertain an action to perpetuate testimony.”1

1 Wright and Miller explain that “[s]ubdivision (c) makes it clear that Rule 27 is not preemptive and does not limit the power of a court to entertain an action to perpetuate testimony. However, the statutory procedure for perpetuation of testimony referred to in the Committee Note to the original rule was repealed by the 1948 revision of Title 28.” 8A Charles A. Wright, Arthur R. Miller & Richard L. Marcus, Federal Practice and Procedure § 2071 (footnotes omitted). IV. DISCUSSION Jones’ labeling of the instant request as a “Verified Petition to Perpetuate

Testimony” at least implies his intent to travel under Rule 27(a). As discussed above, however, Rule 27(a) predicates the authority to file such a “verified petition” on the absence of a pending civil action for which the proposed deposition testimony may be relevant. Because Jones is already a party to the pending civil action for which he seeks to perpetuate testimony, Rule 27(a) has no apparent applicability, and Jones does not argue otherwise. See 8A Charles A. Wright, Arthur R. Miller & Richard L. Marcus, Federal

Practice and Procedure § 2071 (“Rule 27 offers a simple method of perpetuating testimony for use in a future action . . . . Rule 27 provides for depositions prior to institution of an action and pending appeal.”); id. § 2072 (“A proceeding to perpetuate testimony is not based on a pending action[.]”). The only specific Rule 27 provision Jones invokes in his “verified petition,” (see

doc.

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Jones v. Hamm (DEATH PENALTY), Counsel Stack Legal Research, https://law.counselstack.com/opinion/jones-v-hamm-death-penalty-almd-2025.