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879 So. 2d 611

Underwood v. State

Court of Criminal Appeals of Alabama · decided 2003-06-27

Cited by 6 later decisions — most recently April 2014

6 state decisions

Key passage — most relied on by later courts

“"Although the record is silent, and Rule 24.4 requires that the express consent be on the record, we consider the parties' implied consent, that is, their failure to object to the untimeliness of the hearing, as evidence of their express consent to carry the motion for a new trial past the sixtieth day. Although this implied consent is not sufficient according to Rule 24.4, this Court chooses to authorize a more workable procedure for dealing with a hearing on a motion for a new trial conducted after the expiration of the 60-day period in Rule 24.4. Simply remanding this cause for another hearing on the same subject with the same witnesses would be a waste of judicial resources. "Therefore, we remand this cause for the circuit court to determine whether the motion was continued by express agreement of the parties. If the trial court finds that it was, it is to amend the case action summary to reflect that fact."”

quoted by 1 later decision, including Taylor v. State

“3 `Express consent' is defined in Black's Law Dictionary 300 (7th ed.1999), as `[c]onsent that is clearly and unmistakably stated' as contrasted with `implied consent' — `[c]onsent inferred from one's conduct rather than from one's direct expression.'”

quoted by 1 later decision, including Taylor v. State

Relies on State v. Property at 2018 Rainbow Drive · 646 So. 2d 683 - Edgar v. State · 679 So. 2d 1066 - McGiboney v. McGiboney

Good law ✅— No negative treatment on recordhow we know

Decided 2003-06-27

View the full empirical analysis of this case →

¶1

¶2Because this case is factually indistinguishable from Edgar v.State, 646 So.2d 683 (Ala. 1994), we do not have the authority to "authorize a more workable procedure for dealing with a hearing on a motion for a new trial conducted after the expiration of the 60-day period in Rule 24.4[, Ala. R.Crim. P]."879 So.2d at 613. The Alabama Supreme Court promulgated Rule 24.4, Ala. R.Crim. P., and decided Edgar, and we are bound by its decisions. See § 12-3-16, Ala. Code 1975. Furthermore, the majority's decision conflicts with Heard v. State, [Ms. CR-01-1810, August 9, 2002] ___ So.2d ___, ___ (Ala.Crim.App. 2002), in which we stated:

¶3 "[A] motion for a new trial filed pursuant to Rule 24, Ala. R.Crim. P., is deemed denied by operation of law if not ruled on within 60 days from the date of sentencing or if not continued to a date certain upon agreement of the parties and entered of recordbefore the 60-day time period expires.

¶4 "A nunc pro tunc order `cannot be used to enlarge or modify a judgment or to make a judgment say something other than what was originally said.' McGiboney v.McGiboney, 679 So.2d 1066, 1068 (Ala.Civ.App. 1995). The trial court's order attempted to correct a jurisdictional defect, i.e., to restore jurisdiction to the trial court after the posttrial motion had been denied by operation of law pursuant to Rule 24.4, Ala. R.Crim. P. State v. Property at 2018Rainbow Drive, 740 So.2d 1025 (Ala. 1999). The circuit court's order was void. Any order attemptingto extend the 60-day period provided by Rule 24.4,Ala. R.Crim. P., must be entered before the 60-dayperiod expires. Ex parte Caterpillar, Inc., supra [708 So.2d 142 (Ala. 1997)]."

¶5(Emphasis added.) Finally, parties to an action cannot impliedly consent to, and thereby waive, a jurisdictional defect. Based on the Alabama Supreme Court's decision in Edgar, we should remand this case to the trial court for that court to conduct a new hearing. Therefore, I concur in the result. *615

¶6

¶7I agree to remand this case to the trial court, although not for the reason stated by the majority. Based on the record certified to this Court, which contains no indication of an express agreement between the prosecutor and the defendant or the defendant's counsel to carry the motion past the sixtieth day to a date certain, I would remand this case for the trial court to conduct another evidentiary hearing on the motion for a new trial in accordance with the Alabama Supreme Court's opinion in Edgarv. State, 646 So.2d 683 (Ala. 1994), a case materially indistinguishable from the present case.

¶8Furthermore, I note that to the extent the majority may be instructing the trial court to "consider the parties' implied consent, that is, their failure to object to the untimeliness of the hearing, as evidence of their express consent to carry the motion for a new trial past the sixtieth day," 879 So.2d at 613, such an instruction cannot be reconciled with the plain language of Rule 24.4, Ala.R.Crim.P. See Personnel Bd. for Mobile Countyv. Bronstein, 354 So.2d 8 (Ala.Civ.App. 1977), in which the Court of Civil Appeals discussed the "express consent" requirement of Rule 59.1, Ala.R.Civ. P., and Black's LawDictionary 305 (6th ed. 1990), defining "express consent" as "[t]hat directly given, either viva voce or in writing. . . . positive, direct, unequivocal consent, requiring no inference or implication to supply its meaning."3 See also Harrisonv. Alabama Power Co., 371 So.2d 19, 20-21 (Ala. 1979) ("The consent or assent to a continuance of a hearing does not satisfy the requirement that the record show the parties' expressconsent to an extension of the 90-day period" under Rule 59.1.).

¶9

3 "Express consent" is defined in Black's Law Dictionary 300 (7th ed. 1999), as "[c]onsent that is clearly and unmistakably stated" as contrasted with "implied consent" — "[c]onsent inferred from one's conduct rather than from one's direct expression."
*1129

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