A.L.L. v. State

Summary

The Alabama Supreme Court reviewed whether an indictment for vehicular homicide was fatally defective because it did not allege a culpable mental state. The court held that the indictment substantially tracking the vehicular-homicide statute was not fatally defective or void, overruled contrary Court of Criminal Appeals decisions, and reversed and remanded.

Holdings

1. An indictment for vehicular homicide under Ala. Code § 32-5A-192(a) is not fatally defective or void merely because it does not expressly allege a culpable mental state, when it substantially follows the statutory language and sufficiently informs the defendant of the nature of the accusation.
2. Chatman v. State and Burnett v. State were overruled because they misconstrued Ex parte Edwards by treating the omission of a culpable mental state from a vehicular-homicide indictment as jurisdictional and rendering the indictment void.

Questions Presented

1. Whether an indictment for vehicular homicide under Ala. Code § 32-5A-192(a) is fatally defective or void because it does not expressly allege a culpable mental state.
2. Whether Ex parte Edwards required reversal of A.L.L.'s youthful-offender adjudication and permitted the State to reindict him.
3. Whether Chatman v. State and Burnett v. State correctly construed Ex parte Edwards.

Disposition

reversed_and_remanded