State v. B.T.D.

B.T.D. was seventeen-years old when he was charged with committing a felony that resulted in a serious physical injury. Alabama law, codified at section 12-15-204, required B.T.D. to be tried in adult court solely due to his age and the offense with which he was charged. B.T.D. did not receive a hearing or any other procedures to determine whether prosecution in the adult court was appropriate. B.T.D’s trial counsel filed a Motion to Dismiss Indictment and Motion to Declare section 12-15-204 unconstitutional. The Trial Court granted B.T.D.’s motion in part; the court dismissed his indictment, but only found that one provision of section 12-15-204, section (a)(4) under which B.T.D. was charged, unconstitutional. 

The State and B.T.D. appealed to the Court of Criminal Appeals of Alabama. Juvenile Law Center served as co-counsel arguing that the entirety of section 12-15-204 which required young people in Alabama charged with certain crimes to be prosecuted in adult court, was unconstitutional under the Due Process and Equal Protection clauses of the United States Constitution. Section 12-15-204 stripped B.T.D. of the protections of the juvenile justice system and exposed him to the harsh penalties and collateral consequences of the criminal justice system without any procedures. Further, the statute unreasonably treats older teenagers who are 16 to 17-years old, such as B.T.D., differently from younger teenagers 14 to 15-years old who receive a hearing before being prosecuted in the adult criminal justice system even if they are charged with similar serious offenses.

The Court of Criminal Appeals of Alabama held that section 12-15-204 does not violate due process and equal protection principles. The court further held that section 12-15-204(a)(4) specifically is not unconstitutionally vague and overly broad.

Juvenile Law Center served as co-counsel with law firm Blume & Blume in filing a Petition for Writ of Certiorari in the Supreme Court of Alabama. We urged the court to grant review in order to correct the misinterpretation of section 12-15-204(a)(4) as constitutional on due process grounds, and to hold that section unconstitutionally vague or overbroad. 

The Supreme Court of Alabama denied the Petition for Writ of Certiorari.