Alabama v. Ellis

The State of Alabama petitioned for a writ of mandamus to direct the Pike Circuit Court to vacate its order granting Andre Ellis’s motion for a new trial. Ellis was convicted on two counts of first degree rape, and burglary in the second degree. He received an 85-year sentence. Ellis moved for a new trial, alleging, among other things, that the State had failed to disclose crucial evidence in violation of “Brady v. Maryland,” (373 U.S. 83 (1963)). The trial court ordered the State to disclose in camera certain evidence and, after conducting a hearing, entered an order dated May 17, 2013, granting Ellis’s motion for a new trial based on the State’s failure to turn over evidence in violation of Rule 16, Ala. R. Crim. P., and in violation of the principles of law set forth in “Brady.” The State moved for consideration, on which the trial court did not rule. The State argued in its petition for mandamus that the trial court exceeded its discretion and its judicial authority in granting Ellis a new trial because the trial court improperly combed the prosecutor’s files and incorrectly and improperly analyzed the contents in those files. The State also argued that the trial court exceeded its discretion in granting a new trial because Ellis never laid the proper predicate to compel the State to disclose the statements of the victims as required by state case law. Lastly, the State argued that the trial court exceeded its discretion in entering its order granting a new trial with regard to the rape charge involving one of the victims because Ellis made no allegation in his motion for a new trial regarding a discovery violation in the case in which that victim was the named victim nor did the trial court make any findings as to any alleged discovery violation pertaining to that case. Upon further review, the Supreme Court concluded the State failed to present exceptional circumstances justifying the issuance of a writ to direct the trial court to set aside its order granting Ellis’s motion for a new trial.