Code of Alabama

Ala. Code § 12-16-204 (2026)

Concurrence of 12 Jurors Required for Finding of Indictment; Endorsement and Signature of Indictment Generally.

✓ official Alabama Legislature (ALISON) text, current July 2026
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The concurrence of at least 12 grand jurors is necessary to find an indictment, and when so found it must be endorsed “a true bill” and the endorsement signed by the foreman.

(Code 1852, §554; Code 1867, §4104; Code 1876, §4777; Code 1886, §4353; Code 1896, §5039; Code 1907, §7300; Code 1923, §8682; Code 1940, T. 30, §89.)

Notes of Decisions
Cited in 5 cases, 1978–2001 · leading case: Noah v. State, 494 So. 2d 870 (Ala. Crim. App. 1986).
Noah v. State, 494 So. 2d 870 (Ala. Crim. App. 1986). · cites it 4× “Although the foreman did sign the endorsement as a "true bill" in compliance with § 12-16-204, Code of Alabama (1975), he did not participate in either the deliberations or the vote.”
Allen v. State, 380 So. 2d 313 (Ala. Crim. App. 1979). · cites it 2× “" Code of Alabama 1975, § 12-16-202. Further, the concurrence of twelve jurors is required for the finding of an indictment.”
Beck v. State, 365 So. 2d 985 (Ala. Crim. App. 1978). · cites it 2× “This portion of the law has been codified in § 89, Code of Alabama 1940, Recompiled 1958, § 12-16-204, Code of Alabama 1975. See Smith v.”
State v. Jones, 753 So. 2d 1211 (Ala. Crim. App. 1999). · cites it 3× “This portion of the law has been codified in § 89, Code of Alabama 1940, Recompiled 1958, § 12-16-204, Code of Alabama 1975. See Smith v.”
James v. State, 813 So. 2d 841 (Ala. 2001). · cites it 2× “Code 1975, provides: “The concurrence of at least 12 grand jurors is necessary to find an indictment, and when so found it must be endorsed ‘a true bill’ and the endorsement signed by the foreman.” “ ‘In State v. Miller, 3 Ala. 343 , the court held that it was essential to the…”
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