This week a federal court ruled that Alabama death row prisoner Billy Joe Magwood has been illegally sentenced to death and is now entitled to relief. The ruling from the United States Court of Appeals for the Eleventh Circuit comes after Mr. Magwood spent over three decades on Alabama's death row for the 1979 shooting death of an Alabama law enforcement officer. State and federal courts denied relief to Mr. Magwood for years until the United States Supreme Court ruled in 2010 that the case required closer review.
Mr. Magwood was convicted of capital murder and sentenced to death in 1981. Alabama law requires that in order to impose a death sentence, a court must find at least one “aggravating circumstance” listed in the death penalty statute. However, in Mr. Magwood’s case, the sentencing judge imposed the death penalty but did not find that a lawful aggravating circumstance existed.
Mr. Magwood challenged his sentence, but the Alabama Supreme Court decided to permit the death penalty in cases like his, even though it admitted that this went against “a literal and technical reading” of the death penalty statute. In a 2006 case involving a different death row prisoner, the Alabama Supreme Court revisited this rule and ruled that sentencing judges must find one of the aggravating factors listed in the statute in order to impose the death penalty.
The State of Alabama for years fought Mr. Magwood’s ability to challenge his sentence in federal court. In 2010, the United States Supreme Court ruled that Mr. Magwood is entitled to challenge his sentence and ordered the Eleventh Circuit to review the merits of his claim.
Following remand from the United States Supreme Court, the Eleventh Circuit held that the state court decision allowing Mr. Magwood to be sentenced to death without a valid aggravating circumstance violated his rights to due process. The court concluded that Mr. Magwood's death sentence was invalid and unlawful.