Z.J.H. v. State of Alabama

CourtCourt of Criminal Appeals of Alabama
DecidedJune 27, 2025
DocketCR-2023-0302
StatusPublished

This text of Z.J.H. v. State of Alabama (Z.J.H. 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
Z.J.H. v. State of Alabama, (Ala. Ct. App. 2025).

Opinion

Rel: June 27, 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-2023-0302 _________________________

Z.J.H.

v.

State of Alabama

Appeal from Jefferson Circuit Court, Bessemer Division (CC-19-1306 and CC-19-1220)

On Return to Second Remand

MINOR, Judge.

Z.J.H. appeals his convictions for first-degree sodomy, see § 13A-6-

63(a)(3), Ala. Code 1975, and sexual abuse of a child under the age 12

years old, see § 13A-6-69.1, Ala. Code 1975. 1 On appeal, Z.J.H. argues (1)

1On original submission, this Court noticed (1) that there was a

discrepancy between the sentence pronounced at the sentencing hearing CR-2023-0302

that the Jefferson Circuit Court, Bessemer Division, erred by excluding

evidence of H.H.'s alleged prior sexual abuse, (2) that the circuit court

erred by limiting certain expert testimony, (3) that the circuit court erred

by allowing a certified facility dog in the courtroom, (4) that the circuit

court erred by allowing the State to impeach K.H., and (5) that "the jury's

verdicts were not supported by the great weight of the evidence." For the

reasons set forth below, we affirm Z.J.H.'s convictions. But we remand

the case for the circuit court to sentence Z.J.H. to not less than 10 years'

postrelease supervision under § 13A-5-6(c), Ala. Code 1975, for his

for Z.J.H.'s conviction for first-degree sodomy and the sentencing order for that conviction and (2) that the record did not include a written sentencing order for the sexual-abuse conviction. Thus, in September 2024 this Court remanded this cause to the circuit court, by order, with instructions for that court to supplement the record with (1) a corrected sentencing order for the sodomy conviction and (2) a sentencing order for the sexual-abuse conviction. See Rule 10(g), Ala. R. App. P.

On return to remand, although the circuit court submitted a corrected sentencing order for the sodomy conviction, the circuit court did not supplement the record with a sentencing order for the sexual-abuse conviction. This Court, on October 16, 2024, thus remanded this cause to the circuit court, by order, for a second time for that court to supplement the record with a sentencing order for the sexual-abuse conviction. On remand, the circuit court complied with our instructions. (Record on Return to Second Remand, C. 5-6.) The circuit court sentenced Z.J.H. to 20 years' imprisonment on the sodomy conviction and to 10 years' imprisonment on the sexual-abuse conviction. 2 CR-2023-0302

conviction for first-degree sodomy.

FACTS AND PROCEDURAL HISTORY

In November 2018, H.H., who was 10 years old and a fifth grader

at McAdory Elementary, disclosed to her school counselor that her

adoptive brother, 17-year-old Z.J.H., had sexually abused her since she

was in the second grade until about one month before her disclosure.

H.H., who was 14 years old at the time of the trial, testified that on

many occasions Z.J.H. had sexually abused H.H. at their home on Powder

Plant Road in McCalla. H.H. initially told her friends, who, in turn,

alerted the school counselor about the allegations that Z.J.H., along with

"French kiss[ing]" H.H., would "suck [H.H.'s] feet," "make [H.H.] rub

[Z.J.H.'s] private area," and "put it in [H.H.'s] mouth." (R. 884.) H.H. also

had stated that "[Z.J.H.] would make [H.H.] watch [porn videos]." 2 (R.

2When Nashira Palmer, who is employed with the Jefferson County

Department of Human Resources, interviewed H.H. at the school following her disclosures to the school counselor, H.H. stated that "[Z.J.H.] would do things to [H.H.] after they watched […] porn on [Z.J.H.'s] phone." (R. 627.) That same day, Palmer interviewed Z.J.H., who denied the allegations but admitted that "[H.H.] may have walked in on him a time before while he was […] masturbating." (R. 634.) Z.J.H. also admitted to Palmer that he had received counseling for "an issue with porn." (R. 634-35.)

3 CR-2023-0302

885.)

H.H. later told Ammy Swaby, the forensic interviewer at the Clay

House, that "[Z.J.H.] would make [H.H.] rub [Z.J.H.'s] private area until

it leaked and [Z.J.H.] would kiss [H.H.] and suck on [her] feet and [Z.J.H.]

would make [H.H.] sit on [Z.J.H.'s] face." (R. 890-91.) H.H. stated that,

when Z.J.H. made H.H. sit on Z.J.H.'s face, H.H.'s clothes would be off

and that "[Z.J.H.] would lick [H.H.'s] private area." (R. 891.) H.H. stated

that she used the word "leak" because "when [Z.J.H.] would tell [her] to

[rub his thing], [Z.J.H.] would say that." (R. 892.)

H.H. stated that the last time she went into Z.J.H.'s room and

planned to ask Z.J.H. something, Z.J.H. had notes on his stomach that

read "[t]he only way—one way to wake me up is to remove the blanket

and suck me" and another one that read "that's the only way and

underlined only." (R. 892-93.) H.H. stated that she "slid" the notes under

her other adoptive brother K.H.'s door but that K.H. said that he threw

the notes away. (R. 892-94.) H.H. testified that it was not the first time

she had told K.H. about what Z.J.H. had done to H.H. H.H. testified that

4 CR-2023-0302

"[K.H.] told [H.H.] not to tell mom." 3 (R. 898-99.)

In his defense, Z.J.H. denied any inappropriate contact with H.H.

But Z.J.H. admitted that H.H. had walked in on him while he was

masturbating while watching pornography.

A jury convicted Z.J.H. of one count of first-degree sodomy and one

count of sexual abuse of a child less than 12 years old. Z.J.H. now appeals.

I. EVIDENCE OF H.H.'S ALLEGED PRIOR SEXUAL ABUSE

Z.J.H. argues that "[t]he circuit court denied [him] his

constitutional right to present a defense by excluding evidence that H.H.

ha[d] been previously sexually abused." (Z.J.H.'s brief, p. 15.) See Rule

412(b)(3), Ala. R. Evid. Z.J.H. argues that the evidence was relevant

because, he says, it "explained how [H.H.] could have possibly known

about the type of sexual acts alleged apart from the State's position that

Z.J.H. abused H.H." (Z.J.H.'s brief, p. 23.)

Rule 412, Ala. R. Evid., provides:

"(a) Evidence Generally Inadmissible. The following evidence is not admissible in any prosecution for criminal sexual conduct except as provided in sections (b) and (c):

"(1) evidence offered to prove that any

3K.H. denied that H.H. had told him about the sexual abuse or the

incident during which H.H. said she had slid notes under his door. 5 CR-2023-0302

complaining witness[4] engaged in other sexual behavior.

"….

"(b) Exceptions. The following evidence is admissible, if otherwise admissible under these rules:

"(3) evidence the exclusion of which would violate the constitutional rights of the defendant."

The State before trial moved in limine to exclude "any specific

instances of [H.H.'s] sexual behavior and/or sexual predisposition" under

Rule 412 (2d Supp. R. 132). Z.J.H. argued at a pretrial-motion hearing

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