In a case illustrating the tumultuous and complicated proceedings for challenging a death sentence, the Alabama Court of Criminal Appeals recently heard the appeal of Brett Richard Yeiter v. State of Alabama, stemming from Escambia County. Yeiter’s case underscores the critical need to adhere to procedural requirements, especially in cases involving severe sentences.
In October of 2014, Brett Richard Yeiter and his father-in-law, Paul Phillips, began a heated argument at the local church where Phillips preached. Yeiter went home to retrieve his shotgun, fatally shooting Phillips upon his return. At trial, Yeiter’s alcohol consumption and previous felony convictions came to light, leading to a guilty verdict. Yeiter was convicted of capital murder and sentenced to death.
Due to the severity of the sentence, Yeiter filed a myriad of appeals and motions, culminating with the most recent appeal to the Court of Criminal Appeals. Yeiter began challenging his proceedings in August 2016 by filing a motion to disqualify the District Attorney’s Office for the 21st Judicial Circuit. He cited connections between an Assistant District Attorney and the law firm that had represented Yeiter’s wife in divorce proceedings.. This initial motion was denied, however, due to the Assistant District Attorney’s lack of involvement in Yeiter’s criminal prosecution. Yeiter cited precedent to support his argument, but the appellate court distinguished his case, ruling that the alleged conflicting involvement did not affect his criminal charges.
Throughout his case, Yeiter contested actions taken by the State as it progressed beyond jury selection and toward trial. First, Yeiter challenged the denial of his motion for juror questionnaires, but the Court emphasized the broad discretion bestowed on trial courts during jury selection, and found Yeiter failed to provide evidence of error or otherwise object at the time. Yeiter also argued that the trial court erred in allowing the State to remove prospective jurors who were expressly against the death penalty. Again, the Court deferred to the trial court’s broad discretion, finding no error. Yeiter also contended that his right to know jurors’ biases was infringed, noting that the jury foreperson failed to disclose prior arrests in the county. Yeiter failed to allege a meaningful impact on his trial strategy, however, so the Court again found no abuse of discretion.
Yeiter continued to challenge State actions as his case progressed past jury selection and towards trial. Yeiter took issue with the admission of a statement he made on November 3, 2014, claiming the statement was obtained after Yeiter had invoked his right to counsel. The Court admitted the statement regardless, following testimony from the law enforcement officials who heard Yeiter’s statement. Yeiter also contended that the jury should have been instructed on provocation manslaughter. The legal requirements for provocation were discussed, however, and Yeiter, as the initial aggressor, failed to show sufficient evidence to justify such a charge.
Additionally, Yeiter objected to the testimony court’s refusal to allow testimony from the victim’s wife, stating that the victim would not have wanted the death penalty issued. This issue played a significant role in Yeiter’s appeal, with Yeiter arguing that under Alabama law, the family of a victim should be allowed to testify recommending leniency as a mitigating factor. The Court looked to similar precedent, finding that these familial opinions were inadmissible and did not constitute relevant mitigating evidence about the circumstances or defendant’s character. Previous rulings also clarified that all opinions about appropriate punishment were impermissible, regardless of the viewpoints expressed, adding further support to the Court’s denial.
Despite Yeiter’s struggle to succeed on his legal challenges, the Court found procedural errors in Yeiter’s sentencing. §13A-5-47 of the Alabama Code requires trial courts to specify the existence of aggravating and mitigating circumstances. The trial court failed to meet this burden in their sentencing order. Additionally, the Court found that, at the time of Yeiter’s trial, Alabama law provided that the judge, rather than the jury, held the final sentencing decision, rendering the jury’s decision as merely a recommendation. As a result of these sentencing errors, the Court vacated Yeiter’s death sentence and remanded the case for further proceedings to determine a new sentence.
Yeiter’s case, spanning multiple legal topics, illustrates several critical concepts closely related to Alabama criminal law. Brett Richard Yeiter v. State of Alabama highlights the broad discretion of trial courts during the jury selection process, highlighted by the Court’s decision to affirm all trial court actions challenged from this stage. Most importantly, the case emphasizes the critical need for procedural accuracy when handling matters as consequential as a death sentence. Ultimately, the trial court’s failure to conform to all relevant statutes in Yeiter’s sentencing offered a path to legal relief.
If you have a Federal Criminal case, a State Criminal case, a Municipal Case or a Family Law case, contact Joe Ingram or Ingram Law LLC at 205-335-2640. Get Relief * Get Results.