Roderick Byrd v. State of Alabama

CourtCourt of Criminal Appeals of Alabama
DecidedMarch 27, 2026
DocketCR-2023-0545
StatusPublished

This text of Roderick Byrd v. State of Alabama (Roderick Byrd v. State of Alabama) 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
Roderick Byrd v. State of Alabama, (Ala. Ct. App. 2026).

Opinion

Rel: March 27, 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-2023-0545 _________________________

Roderick Byrd

v.

State of Alabama

Appeal from Jefferson Circuit Court (CC-06-2222.60)

MINOR, Judge.

In this appeal we consider whether the Jefferson Circuit Court

erred in summarily dismissing Roderick Byrd's petition for relief under

Rule 32, Ala. R. Crim. P., in which he challenged his 2007 convictions for

four counts of capital murder and his resulting death sentences. On

appeal, Byrd argues: (1) that his petition was timely filed; (2) that he is CR-2023-0545

intellectually disabled and thus ineligible for the death penalty and that

his trial counsel were ineffective in developing and presenting evidence

to show that he is intellectually disabled; (3) that he was constructively

denied counsel; (4) that his trial counsel were ineffective during jury

selection; (5) that his trial counsel were ineffective in negotiating a plea;

(6) that his trial counsel were ineffective during the guilt phase; and (7)

that his trial counsel were ineffective during the penalty phase and at

the sentencing hearing before the trial court. For the reasons below, we

affirm.

FACTS AND PROCEDURAL HISTORY

On direct appeal in 2009, this Court summarized the relevant facts

and procedural history of the proceedings leading to Byrd's convictions

and death sentences:

"On November 24, 2005, Thanksgiving Day, Brandon Mitchell went to Byrd's sister, Hellena Byrd's apartment in Birmingham, Alabama, where Roderick Byrd and Jonathan Floyd also lived. Mitchell woke Byrd and enlisted Byrd's and Floyd's aid in his plan to commit a robbery at the Airport Inn (hereinafter 'the Inn'). After agreeing to help Mitchell commit the robbery, Byrd returned to his bedroom and put on a black shirt, black pants, and black shoes. Shortly thereafter, Floyd drove Mitchell and Byrd to the Inn in Floyd's automobile.

"According to Byrd's statement, while they were in the parking lot of the Inn, Mitchell, Floyd, and Byrd discussed the 2 CR-2023-0545

robbery. At some point before entering the Inn, Byrd put on a pair of black gloves to prevent leaving physical evidence of his participation in the crime; however, neither he nor Mitchell, who had previously been employed at the Inn, made any attempt to conceal their facial identities.1 Thereafter, Mitchell and Byrd entered the Inn—each armed with one pistol—and encountered Kim Olney, the desk clerk, and John Aylesworth, a truck driver, who was waiting in the lobby for a ride to Texas.

"Once in the Inn, Mitchell focused his attention on Olney while Byrd used his pistol to subdue Aylesworth, a former Marine. At some point during the robbery, Dorothy Smith, a traveler from New York who was in Alabama visiting family for Thanksgiving, entered the lobby of the Inn to rent a room for the night. After she entered the lobby, Smith, like Olney and Aylesworth, was held at gunpoint. During this time, Mitchell took approximately $300 from a cash drawer that was located behind the clerk's desk and also tried unsuccessfully to open a safe. Mitchell and Byrd also took various items from the three victims, including a tote bag, a duffel bag, clothes, and money. During these events, Olney, Aylesworth, and Smith were each shot behind the ear at close range with .38 caliber pistols.2 Olney was also shot in the arm. All three victims died as result of a gunshot wound to the head. Forensic testing of the projectiles recovered from the crime scene and the victims' bodies established that Olney and Smith were shot with the same .38 caliber pistol and that Aylesworth was shot with a different .38 caliber pistol.

"After the robbery, Mitchell and Byrd left the Inn on foot. They traveled around to the back of the Inn and climbed a fence that separated the Inn from a neighborhood. Clifford Davis and James Jackson, who lived in one of the houses behind the Inn, saw two men, carrying various items, climb the fence and enter the neighborhood. Although Davis and Jackson could not make a positive identification, they testified that one of the two men they saw climb the fence was wearing 3 CR-2023-0545

all black, including black shoes. Davis and Jackson testified that after the two men climbed the fence and entered the neighborhood, they went in different directions.

"Shortly after Mitchell and Byrd separated, Mitchell telephoned Floyd and asked Floyd to come pick him up. Floyd found Mitchell near First Avenue in Birmingham and drove Mitchell to Fifth Avenue South. Floyd dropped Mitchell off on Fifth Avenue and then drove around looking for Byrd. After unsuccessfully searching for Byrd, Floyd returned to Hellena Byrd's apartment where he found Byrd crying and shaking. At that point, Byrd made a statement to Floyd indicating that Mitchell shot all three people at the Inn.

"Floyd and Byrd remained at the apartment for approximately 30 minutes. Then they, along with Hellena Byrd and Byrd's girlfriend, Lasundra Mosley, went to Byrd's grandmother's house, where they ate Thanksgiving dinner.

"At some point after Thanksgiving, Byrd went to Georgia where he was apprehended. While in Georgia at the Henry County jail, Byrd gave a statement to two Birmingham police officers in which he confessed to participating in the robbery, but denied any involvement in the murders.

"_______________

"1The video of the crime recorded by a security camera shows that Mitchell had a knit cap or ski mask on his head; however, the cap was not covering his face, and he eventually removed it from his head.

"2The security video from the lobby of the Inn shows Mitchell shooting Olney."

Byrd v. State, 78 So. 3d 445, 448-49 (Ala. Crim. App. 2009).

At the penalty phase, the jury recommended, by an 11-1 vote, that 4 CR-2023-0545

Byrd receive a death sentence for counts 1, 2, and 4. As to count 3, the

jury recommended a death sentence by a 10-2 vote. The trial court

followed the jury's recommendation and sentenced Byrd to death on all

four counts.

This Court affirmed Byrd's convictions and death sentences. Byrd,

78 So. 3d 445. The Alabama Supreme Court denied Byrd's petition for

the writ of certiorari. Ex parte Byrd (No. 1081250, Aug. 19, 2011), cert.

denied, Byrd v. Alabama, 565 U.S. 1205 (2012). This Court issued a

certificate of judgment on August 19, 2011, making Byrd's convictions

and sentences final.

In August 2012, Byrd, through counsel, timely filed a postconviction

petition under Rule 32, Ala. R. Crim. P., challenging his convictions and

sentences. (Supp. C. 318.) Over the next decade, the case was reassigned

to different judges. Byrd amended his petition four times, and the State

moved to dismiss each amended petition.

In June 2023, the circuit court summarily dismissed the petition.

(C. 77.) Byrd moved for reconsideration and timely appealed.1 (C. 95,

1The circuit court did not rule on the motion for reconsideration

before it lost jurisdiction to modify its judgment dismissing the petition. 5 CR-2023-0545

928.)

STANDARD OF REVIEW

" '[Byrd] has the burden of pleading and proving his claims. As Rule 32.3, Ala. R. Crim. P., provides:

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