State of Alabama v. Joshua Lamont MacGrady (Appeal from Jefferson District Court: DC-22-1555)

CourtCourt of Criminal Appeals of Alabama
DecidedMay 3, 2024
DocketCR-2023-0867
StatusPublished

This text of State of Alabama v. Joshua Lamont MacGrady (Appeal from Jefferson District Court: DC-22-1555) (State of Alabama v. Joshua Lamont MacGrady (Appeal from Jefferson District Court: DC-22-1555)) 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
State of Alabama v. Joshua Lamont MacGrady (Appeal from Jefferson District Court: DC-22-1555), (Ala. Ct. App. 2024).

Opinion

Rel: May 3, 2024

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, 2023-2024 _________________________

CR-2023-0867 _________________________

State of Alabama

v.

Joshua Lamont MacGrady

Appeal from Jefferson District Court (DC-2022-1555)

On Return to Remand

WINDOM, Presiding Judge. CR-2023-0867

The State of Alabama appeals the Jefferson Circuit Court's order

granting Joshua Lamont MacGrady's motion to dismiss the case against

him. 1

Facts and Procedural History

On December 15, 2021, MacGrady's wife rented a moving truck

from a rental company in Palm Beach County, Florida. The truck was

not returned as scheduled, and the rental company reported the truck as

stolen on January 28, 2022. Law enforcement initiated a traffic stop of

the truck in Jefferson County on February 21, 2022. MacGrady was

Judge Shanta Craig Owens, a Jefferson Circuit Court Judge, 1

signed the orders in this case as a "District Judge." Further, MacGrady's motion and amended motion purported to have been filed in the circuit court, yet the trial court's digital stamp indicated that the motions had been filed in the district court.

Because the case had been bound over to the grand jury before the motion to dismiss had been granted, the district court no longer had jurisdiction of the case. See State v. Brown, 259 So. 3d 655, 659 (Ala. 2018) ("The district court does not retain authority over a case once the case has been bound over to the grand jury."). Accordingly, this Court remanded the case on April 15, 2024, for Judge Owens to clarify whether she was sitting as a circuit judge or acting as a district judge at the time she granted MacGrady's motion to dismiss.

On April 16, 2024, Judge Owens issued an order stating that she was sitting as a circuit judge when she granted MacGrady's motion to dismiss. Presumably, the case still carries a district court case number because the case was dismissed before MacGrady was indicted. 2 CR-2023-0867

driving the truck at the time and was arrested for first-degree receiving

stolen property, see §13A-8-17, Ala. Code 1975.

MacGrady was released on bond on February 24, 2022. On March

28, 2022, MacGrady entered a written demand for a speedy trial.

MacGrady waived his preliminary hearing on May 10, 2022, and the case

was bound over to the grand jury.

On May 16, 2023, MacGrady filed a motion to dismiss the pending

charge because, he argued, his right to a speedy trial had been violated,

and he filed an amended motion on October 17, 2023, that included

several images of what appeared to be emails from a potential employer.

(C. 36-42, 20-29.) The circuit court held a hearing on MacGrady's

amended motion to dismiss on October 19, 2023. In a written order

issued on November 9, 2023, the circuit court granted MacGrady's motion

to dismiss. (C. 12.) The State timely appealed the circuit court's

judgment on November 15, 2023. See Rule 15.7, Ala. R. Crim. P.

Analysis

The State asserts on appeal that the circuit court erred in granting

MacGrady's motion to dismiss because, it argues, MacGrady failed to

prove that he was prejudiced by the delay in bringing him to trial. "The

3 CR-2023-0867

facts before us are undisputed. The only question to be decided is a

question of law, and our review is therefore de novo." Ex parte Heard,

999 So. 2d 978, 980 (Ala. 2003) (citing Ex parte Key, 890 So. 2d 1056,

1059 (Ala. 2003)).

In Ex parte Walker, 928 So. 2d 259 (Ala. 2005), the Alabama

Supreme Court explained:

"An accused's right to a speedy trial is guaranteed by the Sixth Amendment to the United States Constitution and by Art. I, § 6, of the Alabama Constitution, 1901. As noted, an evaluation of an accused's speedy-trial claim requires us to balance the four factors the United States Supreme Court set forth in Barker [v. Wingo, 407 U.S. 514 (1972)]: '[l]ength of delay, the reason for the delay, the defendant's assertion of [his or her] right, and prejudice to the defendant.' 407 U.S. at 530, 92 S. Ct. 2182 (footnote omitted). See also Ex parte Carrell, 565 So. 2d [104,] 105 [(Ala. 1990)]. 'A single factor is not necessarily determinative, because this is a "balancing test, in which the conduct of both the prosecution and the defense are weighed." ' Ex parte Clopton, 656 So. 2d [1243] at 1245 [(Ala. 1995)] (quoting Barker, 407 U.S. at 530, 92 S. Ct. 2182).”

928 So. 2d at 263.

Length of Delay

The first factor to evaluate is the length of the delay. "In Alabama,

'[t]he length of delay is measured from the date of the indictment or the

date of the issuance of an arrest warrant – whichever is earlier.' " Ex

4 CR-2023-0867

parte Walker, 928 So. 2d at 264 (quoting Roberson v. State, 864 So. 2d

379, 394 (Ala. Crim. App. 2002)). MacGrady was arrested for first-degree

receiving stolen property on February 21, 2022, and the circuit court held

a hearing on his motion to dismiss on October 19, 2023.2 The delay in

this case was approximately 20 months.

In prior cases, this Court has held similar delays to be

presumptively prejudicial. See State v. Pylant, 214 So. 3d 392, 395 (Ala.

Crim. App. 2016), and the cases cited therein.

"A finding that the length of delay is presumptively prejudicial 'triggers' an examination of the remaining three Barker factors. 505 U.S. at 652 n.1, 112 S. Ct. 2686 ('[A]s the term is used in this threshold context, "presumptive prejudice" does not necessarily indicate a statistical probability of prejudice; it simply marks the point at which courts deem the delay unreasonable enough to trigger the Barker enquiry.'). See also Roberson v. State, 864 So. 2d 379, 394 (Ala. Crim. App. 2002)."

Ex parte Walker, 928 So. 2d at 263-64. Because the length of delay in

MacGrady's case was presumptively prejudicial, this Court will examine

the remaining Barker v. Wingo, 407 U.S. 514 (1972), factors.

2 It does not appear from the record that MacGrady has been indicted. 5 CR-2023-0867

Reasons for the Delay

Returning to Ex parte Walker:

"The State has the burden of justifying the delay. See Barker, 407 U.S. at 531; Steeley v. City of Gadsden, 533 So. 2d 671, 680 (Ala. Crim. App. 1988). Barker recognizes three categories of reasons for delay: (1) deliberate delay, (2) negligent delay, and (3) justified delay. 407 U.S. at 531. Courts assign different weight to different reasons for delay. Deliberate delay is 'weighted heavily' against the State. 407 U.S. at 531.

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Related

United States v. Bergfeld
280 F.3d 486 (Fifth Circuit, 2002)
United States v. Ewell
383 U.S. 116 (Supreme Court, 1966)
Smith v. Hooey
393 U.S. 374 (Supreme Court, 1969)
United States v. Marion
404 U.S. 307 (Supreme Court, 1971)
Barker v. Wingo
407 U.S. 514 (Supreme Court, 1972)
Arizona v. Youngblood
488 U.S. 51 (Supreme Court, 1989)
Doggett v. United States
505 U.S. 647 (Supreme Court, 1992)
United States v. Brian Brown
169 F.3d 344 (Sixth Circuit, 1999)
Ex Parte Heard
999 So. 2d 978 (Supreme Court of Alabama, 2003)
Wilson v. State
407 So. 2d 584 (Court of Criminal Appeals of Alabama, 1981)
McCallum v. State
407 So. 2d 865 (Court of Criminal Appeals of Alabama, 1981)
Kelley v. State
568 So. 2d 405 (Court of Criminal Appeals of Alabama, 1990)
State v. Jones
35 So. 3d 644 (Court of Criminal Appeals of Alabama, 2009)
Steeley v. City of Gadsden
533 So. 2d 671 (Court of Criminal Appeals of Alabama, 1988)
Zumbado v. State
615 So. 2d 1223 (Court of Criminal Appeals of Alabama, 1993)
Ex Parte Key
890 So. 2d 1056 (Supreme Court of Alabama, 2003)
Ex Parte Walker
928 So. 2d 259 (Supreme Court of Alabama, 2005)
Roberson v. State
864 So. 2d 379 (Court of Criminal Appeals of Alabama, 2002)

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State of Alabama v. Joshua Lamont MacGrady (Appeal from Jefferson District Court: DC-22-1555), Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-alabama-v-joshua-lamont-macgrady-appeal-from-jefferson-district-alacrimapp-2024.