K.A. v. State of Alabama (Appeal from Russell Juvenile Court: JU-23-748.03)

CourtCourt of Criminal Appeals of Alabama
DecidedMarch 28, 2025
DocketCR-2024-0329
StatusPublished

This text of K.A. v. State of Alabama (Appeal from Russell Juvenile Court: JU-23-748.03) (K.A. v. State of Alabama (Appeal from Russell Juvenile Court: JU-23-748.03)) 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
K.A. v. State of Alabama (Appeal from Russell Juvenile Court: JU-23-748.03), (Ala. Ct. App. 2025).

Opinion

Rel: March 28, 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-2024-0329 _________________________

K.A.

v.

State of Alabama

Appeal from Russell Juvenile Court (JU-23-748.03)

KELLUM, Judge.

K.A. was adjudicated delinquent on the underlying charge of

murder made capital because it was committed during the course of a CR-2024-0329

robbery in the first degree. 1 See § 13A-5-40(a)(2), Ala. Code 1975. The

juvenile court found K.A. to be a serious juvenile offender and committed

him to the custody of the Department of Youth Services ("DYS") until his

21st birthday.

At the delinquency hearing, the State presented evidence

indicating that, on December 12, 2023, K.A. and J.S. robbed at gunpoint

Douglas Rutledge as he was walking down the street by Synovus Bank

in Phenix City. One pointed the gun at Rutledge while the other checked

Rutledge's pockets. K.A. and J.S. then ran away, and Rutledge continued

walking. A short time later, a little after 7:00 p.m., just after Ryan Boles

got into his vehicle parked behind Synovus Bank, K.A. ran up, opened

the driver's door, and shot Boles. The autopsy revealed that the bullet

1In the same proceeding, in case no. JU-23-748.04, K.A. was tried

for a robbery that occurred only a few minutes before the murder, and the juvenile court purported to adjudicate him delinquent of attempted robbery as a lesser-included offense of the robbery charge. See, e.g., Pilgrim v. State, 963 So. 2d 697, 700 (Ala. Crim. App. 2006) ("[A]fter the effective date of the Criminal Code [January 1, 1980,] attempted robbery [i]s no longer a criminal offense in Alabama."). K.A. listed on his notice of appeal, however, only case no. JU-23-748.03, the case number associated with his adjudication for capital murder. Therefore, this appeal is solely from his adjudication for capital murder.

2 CR-2024-0329

passed through Boles's left arm and entered his chest, where it punctured

his heart, lung, diaphragm, and liver.

Surveillance cameras from the bank and another nearby business

captured both the robbery of Rutledge and the murder of Boles. K.A. was

identified from that surveillance footage as one of the participants in the

crimes based on the distinctive clothing that he was wearing at the time 2

and based on Robert Isabel, a lieutenant with the Phenix City Police

Department, recognizing K.A., whom he knew personally. Specifically,

testimony indicated that K.A. had received the Reebok brand black and

gray jacket and the joggers with writing down the side that he was

wearing the night of the shooting only a few days earlier as Christmas

presents from a youth camp that he regularly attended and where Lt.

Isabel volunteered. K.A. later gave a statement to investigators, in which

he confessed to shooting Boles, claiming that the gun belonged to J.S. and

that, "if he didn't do what he did, then [J.S.] was going to kill him that

night." (R. 387.)

I.

2J.S. was also identified based on his clothing as seen in the surveillance footage.

3 CR-2024-0329

K.A. contends that the juvenile court erred in denying his motion

to suppress the statement he made to investigators because, he says, he

did not knowingly and voluntarily waive his rights. He argues that he

was only 13 years old, had completed only the 6th grade, and had not

taken any classes in school about his constitutional rights. He also

argues that he did not verbally acknowledge that he understood his

rights during the interview and that his aunt testified that she did not

believe he understood his rights. Thus, he concludes, he was too young

and lacking in knowledge to knowingly and voluntarily waive his rights.

At the suppression hearing and at the delinquency hearing, the

State presented evidence indicating that Lt. Isabel and Deon San

Nicolas, an investigator with the Phenix City Police Department,

interviewed K.A. Inv. San Nicolas advised K.A. of his juvenile Miranda

rights. 3 Inv. San Nicolas said that, when asked if he understood his

rights, K.A. nodded his head and then signed a waiver-of-rights form.4

3See Miranda v. Arizona, 384 U.S. 436 (1966), and § 12-15-202, Ala.

Code 1975.

4After watching the video of the interview, the juvenile court agreed

that K.A. had nodded his head, albeit slightly, after being asked if he understood his rights. This Court has also watched the video, and we agree with the juvenile court. 4 CR-2024-0329

According to Inv. San Nicolas, K.A. appeared to understand his rights

and never indicated otherwise and at no point during the interview did

K.A. refuse to answer questions or request to speak to a lawyer or a

parent. In addition, Inv. San Nicolas stated that no promises or threats

were made to induce K.A. to give a statement.

Rayshawnda Hicks, K.A.'s aunt, testified at the suppression

hearing that K.A. had lived with her from the fourth grade to the sixth

grade, which concluded in May before the murder in December 2023.

Hicks testified that she did not remember K.A.'s having taken any classes

in which he learned about government or the United States Constitution.

She also testified that she had had no discussions with K.A. about his

constitutional rights, and, because of that, she did not "think he would

understand or he understood" his constitutional rights. (R. 45.) Hicks

admitted, however, that K.A. understood the English language and that

he had no trouble understanding her when she spoke to him.

"To establish a proper Miranda predicate, the State must prove that 'the accused was informed of his Miranda rights before he made the statement' and that 'the accused voluntarily and knowingly waived his Miranda rights before making his statement.' Jones v. State, 987 So. 2d 1156, 1164 (Ala. Crim. App. 2006). 'Whether a waiver of Miranda rights is voluntarily, knowingly, and intelligently made depends on the facts of each case, considering the totality of the

5 CR-2024-0329

circumstances surrounding the interrogation, including the characteristics of the accused, the conditions of the interrogation, and the conduct of the law-enforcement officials in conducting the interrogation.' Foldi v. State, 861 So. 2d 414, 421 (Ala. Crim. App. 2002)."

Wilkerson v. State, 70 So. 3d 442, 460 (Ala. Crim. App. 2011).

The evidence established that K.A. was properly advised of his

juvenile Miranda rights, that he nodded his head when asked if he

understood those rights, that he signed a waiver-of-rights form, and that

no threats or promises were made to get K.A. to waive his rights or to

give his statement. At no time did K.A.

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Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Glen Dale Castle v. United States
399 F.2d 642 (Fifth Circuit, 1968)
Foldi v. State
861 So. 2d 414 (Court of Criminal Appeals of Alabama, 2002)
Pilgrim v. State
963 So. 2d 697 (Court of Criminal Appeals of Alabama, 2006)
Williams v. State
420 So. 2d 91 (Court of Criminal Appeals of Alabama, 1982)
Jones v. State
987 So. 2d 1156 (Court of Criminal Appeals of Alabama, 2006)
Locke v. Wheat
350 So. 2d 451 (Supreme Court of Alabama, 1977)
Federal Labor Union 23393 v. American Can Co.
100 A.2d 693 (New Jersey Superior Court App Division, 1953)
Wilkerson v. State
70 So. 3d 442 (Court of Criminal Appeals of Alabama, 2011)
T.L.S. v. State
153 So. 3d 829 (Court of Criminal Appeals of Alabama, 2013)
Q.S. v. State
188 So. 3d 710 (Court of Criminal Appeals of Alabama, 2015)
T.D.B. v. State
195 So. 3d 314 (Court of Criminal Appeals of Alabama, 2015)
State v. R.C.
195 So. 3d 317 (Court of Criminal Appeals of Alabama, 2015)
S.F.R. v. State
598 So. 2d 1006 (Supreme Court of Alabama, 1992)
R.E.C. v. State
678 So. 2d 1041 (Supreme Court of Alabama, 1995)
B.W. v. State
834 So. 2d 816 (Court of Criminal Appeals of Alabama, 2001)

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K.A. v. State of Alabama (Appeal from Russell Juvenile Court: JU-23-748.03), Counsel Stack Legal Research, https://law.counselstack.com/opinion/ka-v-state-of-alabama-appeal-from-russell-juvenile-court-ju-23-74803-alacrimapp-2025.