Ex Parte State of Alabama. (in Re Lam Luong v. State of Alabama)

Summary

The Alabama Supreme Court reversed the Court of Criminal Appeals and remanded, holding that the trial court did not err in refusing to change venue despite extensive pre‑trial publicity, did not exceed its discretion by denying individual voir dire, properly denied counsel’s request for mitigation‑travel funds, and correctly admitted a videotape demonstration at sentencing. The Court applied an abuse‑of‑discretion standard and found no presumption of prejudice. Justice Parker and Justice Murdock dissented, arguing that the trial court should have found presumed prejudice and required individualized voir dire.