Ex Parte Christopher Lee Price. (Re Christopher Lee Price v. State).

Summary

The Supreme Court of Alabama affirmed Christopher Lee Price's capital murder conviction and death sentence, along with his first-degree robbery conviction and life-without-parole sentence, on certiorari review. The Court held that the State adequately proved Miranda warnings preceded Price's Tennessee statement, which was voluntary and properly admitted, but that the State failed to prove adequate warnings preceded his Alabama statement because testimony that he was 'Mirandized' from an unidentified form was legally insufficient. That deficiency, however, did not amount to plain error because the Alabama statement itself was never admitted, the testimony derived from it was cumulative of the properly admitted Tennessee statement, and the remaining evidence of guilt was overwhelming. Statutory death-sentence review disclosed no arbitrary factor, supported the two aggravating circumstances, and found the sentence proportionate.