Jammie LaJoyce Hughes v. State of Alabama

── Jammie LaJoyce Hughes v. State of Alabama ── Case No.: CR-2024-0935 Court: Court of Criminal Appeals of Alabama Date: March 27, 2026 Author: Anderson 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-2024-0935 _________________________ Jammie LaJoyce Hughes v. State of Alabama Appeal from Jefferson Circuit Court, Bessemer Division (CC-20-466) ANDERSON, Judge. Jammie LaJoyce Hughes appeals her conviction for murder, a violation of § 13A-6-2(a)(1), Ala. Code 1975, and her resulting sentence as a habitual felony offender to life imprisonment. For the reasons that CR-2024-0935 follow, we reverse the judgment of the Jefferson Circuit Court, Bessemer Division. Facts and Procedural History On October 22, 2020, Hughes was indicted by a Jefferson County grand jury on one count of intentional murder, see § 13A-6-2(a)(1), Ala. Code 1975, for the stabbing death of Sidell Alstan Erskine on October 3, 2019. Because Hughes does not challenge the sufficiency of the evidence in this case, a brief recitation of the facts in this case is all that is required. Jasmine Whitworth, Hughes's friend, testified that, on the afternoon of October 3, 2019, she was on the porch of Hughes's house with Whitworth's two children, waiting for Hughes to return home. Erskine came out of the door and told Whitworth that Hughes was not home yet and that Hughes "need[ed] to hurry up." (R. 267.) Whitworth stated that Erskine then went back inside the house and closed the door. Whitworth called Hughes, who explained that she was about to pull up at the house. When Hughes arrived, she told Whitworth and her two children to get into Hughes's vehicle to ride along while she drove Erskine to work. Whitworth and her two children got into the backseat of Hughes's 2 CR-2024-0935 vehicle. Erskine then got into the vehicle and threw Hughes's purse. Whitworth stated that Hughes asked Erskine what was wrong and why he had thrown her purse. Whitworth testified that, as Hughes began to pull off, Erskine got out of the vehicle, slammed the vehicle's door, and returned inside the house. According to Whitworth, Hughes then returned inside the house to see whether Erskine was still going to go to work; however, after Hughes went inside the house, Erskine came outside, got into the driver's side of the vehicle, and began driving away from the house and toward a stop sign, with Whitworth and her children still in the backseat of the vehicle. Whitworth explained that Erskine then stated "y'all ain't got nothing to do with this … I ain't fixing to kidnap y'all" (R. 269) before turning around to go back toward the house. While Whitworth was in the vehicle with Erskine, Hughes called Whitworth, crying, and stated that Erskine had slapped her. When Erskine pulled back up to the house, Hughes was standing outside the house in the yard. Erskine returned inside the house, and Hughes got into the driver's seat of the vehicle. Hughes told Whitworth that she was tired, that she was going to leave, and that Erskine was "not going to hit [her] anymore." (R. 271.) Whitworth 3 CR-2024-0935 claimed that, at that point, she explained to Hughes that Erskine had grabbed the vehicle's keys before he returned inside the house,