Sheffield v. Alabama

James Sheffield was indicted on two counts of reckless murder for intentionally setting fire to a cushion he had placed underneath a house that caused a house to catch fire, killing two persons inside the house. Sheffield was convicted of reckless murder on count I (for the death of Charles Morrow, Jr.) and of the lesser-included offense of manslaughter on count II (the death of Charles Morrow III). He was sentenced to 50 years in prison on the reckless murder conviction and to 17 years on the manslaughter conviction, the sentences to run consecutively. Sheffield appealed. On appeal, the Court of Criminal Appeals affirmed the manslaughter conviction on count II but reversed the reckless murder conviction on count I and remanded the case for the circuit court to enter a judgment finding Sheffield guilty of manslaughter on count I and to resentence Sheffield accordingly. On remand, the circuit court entered a judgment convicting Sheffield of manslaughter as to count I. The circuit court then sentenced Sheffield to 17 years' imprisonment for his conviction on count I, the sentence to run consecutively to Sheffield's 17-year sentence on his count II manslaughter conviction. Sheffield appealed again, challenging the sentencing order and contending that the circuit court erred when it imposed consecutive sentences for multiple convictions arising out of a single act. The Court of Criminal Appeals dismissed the appeal on the basis that it lacked jurisdiction to hear an appeal from a sentencing order such as the one at issue here. Sheffield contended on appeal to the Supreme Court, and the State agreed, that the Court of Criminal Appeals had jurisdiction to consider Sheffield's appeal challenging the new sentence imposed by the circuit court on remand. The Supreme Court also agreed, reversed the appellate court and remanded the case for further proceedings. View "Sheffield v. Alabama " on Justia Law