Roderick Byrd v. State of Alabama

── Roderick Byrd v. State of Alabama ── Case No.: CR-2023-0545 Court: Court of Criminal Appeals of Alabama Date: March 27, 2026 Author: Minor Category: General Rel: March 27, 2026 Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is published in Southern Reporter. Alabama Court of Criminal Appeals OCTOBER TERM, 2025-2026 _________________________ CR-2023-0545 _________________________ Roderick Byrd v. State of Alabama Appeal from Jefferson Circuit Court (CC-06-2222.60) MINOR, Judge. In this appeal we consider whether the Jefferson Circuit Court erred in summarily dismissing Roderick Byrd's petition for relief under Rule 32, Ala. R. Crim. P., in which he challenged his 2007 convictions for four counts of capital murder and his resulting death sentences. On appeal, Byrd argues: (1) that his petition was timely filed; (2) that he is CR-2023-0545 intellectually disabled and thus ineligible for the death penalty and that his trial counsel were ineffective in developing and presenting evidence to show that he is intellectually disabled; (3) that he was constructively denied counsel; (4) that his trial counsel were ineffective during jury selection; (5) that his trial counsel were ineffective in negotiating a plea; (6) that his trial counsel were ineffective during the guilt phase; and (7) that his trial counsel were ineffective during the penalty phase and at the sentencing hearing before the trial court. For the reasons below, we affirm. FACTS AND PROCEDURAL HISTORY On direct appeal in 2009, this Court summarized the relevant facts and procedural history of the proceedings leading to Byrd's convictions and death sentences: "On November 24, 2005, Thanksgiving Day, Brandon Mitchell went to Byrd's sister, Hellena Byrd's apartment in Birmingham, Alabama, where Roderick Byrd and Jonathan Floyd also lived. Mitchell woke Byrd and enlisted Byrd's and Floyd's aid in his plan to commit a robbery at the Airport Inn (hereinafter 'the Inn'). After agreeing to help Mitchell commit the robbery, Byrd returned to his bedroom and put on a black shirt, black pants, and black shoes. Shortly thereafter, Floyd drove Mitchell and Byrd to the Inn in Floyd's automobile. "According to Byrd's statement, while they were in the parking lot of the Inn, Mitchell, Floyd, and Byrd discussed the 2 CR-2023-0545 robbery. At some point before entering the Inn, Byrd put on a pair of black gloves to prevent leaving physical evidence of his participation in the crime; however, neither he nor Mitchell, who had previously been employed at the Inn, made any attempt to conceal their facial identities.1 Thereafter, Mitchell and Byrd entered the Inn—each armed with one pistol—and encountered Kim Olney, the desk clerk, and John Aylesworth, a truck driver, who was waiting in the lobby for a ride to Texas. "Once in the Inn, Mitchell focused his attention on Olney while Byrd used his pistol to subdue Aylesworth, a former Marine. At some point during the robbery, Dorothy Smith, a traveler from New York who was in Alabama visiting family for Thanksgiving, entered the lobby of the Inn to rent a room for the night. After she entered the lobby, Smith, like Olney and Aylesworth, was held at gunpoint. During this time, Mitchell took approximately $300