Summary
The Supreme Court of Alabama affirmed the transfer of 14-year-old E.J.M.'s capital-murder case from juvenile court to circuit court for prosecution as an adult. The court held that due process did not require the State to fund a mental-health expert of the juvenile's choosing when the juvenile court had provided an independent, court-appointed mental-health evaluation. The court also distinguished Ex parte H.P.W. from L.L.J. v. State and declined to overrule H.P.W.
Topics
Practice areas
Questions Presented
- Whether the transfer of E.J.M.'s juvenile case to circuit court conflicted with the due-process requirements recognized in Kent v. United States.
- Whether Ex parte H.P.W. was inconsistent with L.L.J. v. State and should be overruled.
- Whether due process required the State to fund a mental-health expert selected by E.J.M. in addition to the independent, court-appointed mental-health evaluation provided by the juvenile court.
Holdings
- The transfer proceeding did not conflict with Kent because the juvenile court held a transfer hearing, ruled on motions, provided counsel, and provided a state-funded psychiatric evaluation; the proceeding therefore lacked none of the basic procedural protections condemned in Kent.
- Ex parte H.P.W. and L.L.J. v. State are not inconsistent because they involved different rights and materially different facts: L.L.J. concerned the right to present a privately retained expert to rebut State witnesses, while H.P.W. concerned a request for public funds for a second, privately selected expert after an independent court-appointed evaluation.
- Due process does not require the State to pay for a mental-health expert of an indigent juvenile's choosing when the juvenile court has provided a competent, independent, court-appointed psychiatrist or other qualified mental-health examiner at State expense.
Key quotations
“Instead, the issue before us is whether due process requires the expenditure of State funds to pay for a mental-health expert of the juvenile's choosing when the juvenile court has provided the juvenile with a court-appointed, independent psychiatrist. There is no such requirement.” (928 So. 2d at 1087)
“In accordance with H.P.W., we hold that the juvenile court's denial of E.J.M.'s request for State funds to pay for a psychological expert of his choosing did not violate his due-process rights.” (928 So. 2d at 1088)
Factual background
E.J.M., who was 14 years old, was accused of participating in the robbery and killing of Cole Cannon, including striking Cannon, taking money and property, and setting fires in Cannon's mobile home. Cannon died from smoke inhalation, with blunt-force head trauma contributing to his death. Before the juvenile transfer hearing, E.J.M. sought state funds for a mental-health expert of his own choosing, but the juvenile court denied the request and instead provided a state-funded independent psychological evaluation by Dr. Brent Willis, who concluded that E.J.M. was sufficiently emotionally mature for transfer and competent to stand trial.
Procedural history
The Lawrence County Juvenile Court transferred E.J.M.'s case to the Lawrence Circuit Court after a transfer hearing. The Court of Criminal Appeals affirmed without opinion. The Supreme Court of Alabama granted E.J.M.'s petition for a writ of certiorari and affirmed.