**Rule 32.1(b) Filing

This is the filing that changes everything. It forces the one question that was never answered in twenty years. Did Alabama ever prove it had the authority to try this case. The answer is no.

This Rule 32.1(b) petition is being filed with the State, but it will also become a standalone exhibit in the federal record because the State has never adjudicated jurisdiction. That matters. A federal judge cannot defer to a State ruling that never happened. When a jurisdiction issue is raised without any prior State decision, the federal court must review it fresh.

Alabama can only prosecute a homicide if the act that caused death happened inside Alabama. The State admitted that burden during trial. Then it failed to meet it. There is no Alabama crime scene, no Alabama medical evidence, no Alabama cause of death, no Alabama time of death and no witness placing any fatal act in Alabama. Every official fact lives in Mississippi. The recovery. The autopsy. The death certificates. The documented cause of death.

Nothing in the record places the homicide in Alabama. Nothing gives the Baldwin County court authority to enter a conviction. Jurisdiction was never ruled on at trial, never addressed on appeal and never raised in any State filing until now. Rule 32.1(b) allows this because a court without authority cannot produce a valid judgment.

If this petition is correct, the State does not get a chance to prove jurisdiction twenty years later. The burden was theirs at trial. They failed. A conviction entered without jurisdiction is void. The only legal remedy is to vacate it.

This filing places that truth on the record for the first time. It stands on its own in State court and it will also carry full weight in federal court because the underlying issue has never been adjudicated.