On December 12, 2023, in Phenix City, Alabama, K.A. and a teenage friend encountered Douglas Rutledge walking outside a Synovus Bank. K.A., who was just 13 years old at the time, and his friend were both armed and made a decision that would ultimately result in the tragic death of Ryan Boyles. Around 7:00 p.m., the two boys robbed their first victim at gunpoint. They then moved into the bank’s parking lot, where they saw Boyles’s car. The boys forced open the door and fatally shot Boyles in the parking lot. K.A. was quickly identified through the bank’s security footage and arrested. After his arrest, K.A. was read his Miranda rights, including the right to remain silent and the right against self-incrimination. When asked by an officer if he understood these rights, he nodded his head and then signed a waiver of rights form.

After waiving his rights, K.A. gave a voluntary statement to investigators, admitting that the gun belonged to his friend and stating, “If he didn't do what he did, then [J.S.] was going to kill him that night.” K.A. v. State, No. CR-2024-0329, 2025 WL 940865, at *1 (Ala. Crim. App. Mar. 28, 2025). During the interview, K.A. never refused to answer a question, and officers later testified that no promises or threats were made to induce his statements. Following these events, “the juvenile court found K.A. to be a serious juvenile offender and committed him to the custody of the Department of Youth Services (‘DYS’) until his 21st birthday.” Id. K.A. appealed this decision to the Alabama Court of Criminal Appeals, arguing that “the juvenile court erred in denying his motion to suppress” and that “the juvenile court erred in ordering that he be committed to DYS until his 21st birthday.” Id.

On March 28, 2025, the Alabama Court of Criminal Appeals held that “Under the circumstances in this case, we have no trouble concluding that K.A. knowingly and voluntarily waived his juvenile Miranda rights. Therefore, the juvenile court properly denied K.A.’s motion to suppress.” Id. However, the court remanded the case to the “juvenile court to set aside its order of commitment and to resentence K.A. and issue a commitment order that complies with Ex parte R.E.C.” Id. Both decisions provide insight into how the juvenile court system in Alabama processes serious offenses involving juvenile defendants, balancing procedural safeguards with the need for appropriate sentencing.

Under Alabama law, for a defendant to validly waive his rights, “the State must prove that ‘the accused was informed of his Miranda rights before he made the statement’ and that ‘the accused voluntarily and knowingly waived his Miranda rights before making his statement.’” Jones v. State, 987 So. 2d 1156, 1164 (Ala. Crim. App. 2006). Affirmative nodding of the head “when asked if [the juvenile] understood his rights as well as his signature at the bottom of the waiver form ... indicate that [the juvenile] was aware of his rights but chose to waive them.” State v. R.C., 195 So. 3d 317, 323–24 (Ala. Crim. App. 2015). In this case, K.A. both nodded his head in response to being asked if he understood his rights and signed a form waiving them. Therefore, “in this case, we have no trouble concluding that K.A. knowingly and voluntarily waived his juvenile Miranda rights.” K.A. v. State, WL 940865, at *2. Accordingly, the court affirmed the lower court’s decision as to K.A.’s first argument. Id.

Under Alabama law, when strictly interpreted, the Juvenile Justice Act prohibits the court from committing a juvenile offender to the Department of Youth Services (DYS) for more than one year. § 12-15-101 et seq., Ala. Code 1975. However, the Alabama Supreme Court has held that a determinate commitment is permissible under the Juvenile Justice Act—even for a nonserious juvenile offender—if the juvenile court makes specific findings. Ex parte R.E.C., 678 So. 2d 1041, 1045 (Ala. 1995). The Court “noted that an order committing a nonserious juvenile offender to the custody of DYS until his 21st birthday” was allowed under Ex parte R.E.C. K.A. v. State, WL 940865, at *7. However, to commit a juvenile until his 21st birthday under Ex parte R.E.C., the State is required to show how such a commitment would benefit the child. Id. In this case, the trial court failed to make any such finding. As a result, the Alabama Court of Criminal Appeals held that the trial court failed to comply with the requirements of Alabama law when sentencing K.A. Id. Accordingly, the Court held: “we remand this case for the juvenile court to set aside its order of commitment and to resentence K.A. and issue a commitment order that complies with Ex parte R.E.C.” Id.

The Alabama Court of Criminal Appeals was forced to balance three competing interests: delivering justice for the victims of a deadly crime, upholding constitutional protections, and attempting to rehabilitate a child. These goals can often be mutually exclusive. The court cannot fully pursue rehabilitation for a 13-year-old while simultaneously providing what some may view as full justice for the family of the man he killed. There is no perfect answer, only a series of difficult choices arising from a tragic situation. Had the court charged K.A. as an adult, it might have satisfied a sense of justice. But doing so would have placed the long-term burden on the state to incarcerate someone for the rest of his life, based on a decision he made under peer pressure at just 13 years old. While the court’s decision may appear lenient, we cannot forget the gravity of the crime: K.A. took a man’s life, ending all of that man’s hopes, dreams, and aspirations. Despite that, the court chose to give K.A. a chance to preserve his own.

Amid this complex decision, the court also had to weigh the constitutional protections afforded to a child accused of a serious crime. This aspect of the case received relatively little attention in the opinion, which focused primarily on sentencing. But it should not be lost in the weeds. If K.A. did not fully understand that he was waiving his rights and incriminating himself, that would represent a violation of the U.S. Constitution. More careful analysis of this issue was warranted, even if the court ultimately reached the correct result. This case represents a tragic event with no easy answers. When sentencing a 13-year-old like K.A., the court is not choosing between right and wrong, but between competing harms. There are only trade-offs.

If you have a Federal Criminal case, a State Criminal case, a Municipal Case or a Family Law case, contact Joe Ingram or Joe Joe Ingram Law, LLC at 205-335-2640. Get Relief * Get Results.