State of Alabama v. Bonnie Lee Baker

Double Springs, Alabama criminal defense lawyer represented the Defendant charged with third-degree escape and operating amortor vehicle without insurance.



In April 2022, Deputy Tim Williams, who was employed with the Addison Police Department, was patrolling an area in Winston County near County Road 41 when he observed a vehicle parked on the side of the road with a low light emitting from the back seat and the passenger rear door open. Deputy Williams stopped and observed Baker bent over in the back seat and looking around. Deputy Williams asked Baker to step out of the vehicle and asked her what she was doing. Baker stated that the vehicle had run out of gas, that she was trying to get it home, and that she had left a note about the vehicle at the house at that address.



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Legal issue Was there sufficient evidence to support a conviction for third-degree escape when the defendant fled before being physically restrained or submitting to arrest?

Headnote



CRIMINAL LAW. EVIDENCE ADMISSIBILITY. The case examines whether the circuit court erred by admitting an excerpt of a transcript from a pretrial status conference as evidence, allegedly in violation of rules concerning plea discussions.



CRIMINAL LAW. SUFFICIENCY OF EVIDENCE. The case addresses whether the State presented sufficient evidence to support the defendant's conviction for operating a motor vehicle without insurance under § 32-7A-16, Ala. Code 1975.



CRIMINAL LAW. THIRD-DEGREE ESCAPE. The court evaluates whether the defendant was in "custody" as defined by § 13A-10-33, Ala. Code 1975, at the time of her alleged escape, ultimately concluding that the State failed to provide sufficient evidence of custody.



Key Phrases Third-degree escape. Operating a motor vehicle without insurance. Habitual Felony Offender Act. Sufficiency of the evidence. Pretrial status conference.

Affirmed in part and reversed in part.