signature defense in Alabama

2003"In Brewer v. State, 440 So.2d 1155 (Ala.Cr.App.1983), this court stated: "`One of the common threads running through all of the treatise-writers' explanations of the signature exception is that a strict test of similarity between the charged and non-charged offenses should be applied.

1993In Brewer v. State , 440 So.2d 1155 (Ala.Cr.App. 1983), this court stated: "One of the common threads running through all of the treatise-writers' explanations of the signature exception is that a strict test of similarity between the charged and non-charged offenses should be applied.

2002Dunnavant v. Dunnavant, 668 So.2d 851 (Ala.Civ.App.1995).

2002Dunnavant v. Dunnavant, 668 So.2d 851 (Ala.Civ.App.1995).

2002In Becker v. Montgomery , 532 U.S. 757 (2001), the United States Supreme Court stated: "Petitioner Dale G.

1999In determining whether the signature requirement is among the "essential requirements of the absentee voting law," id., we are not without legislative guidance.

1988Johnson denied that the signature on the waiver of rights was his own. 2 "It is not the right to counsel that the Fifth Amendment protects but the freedom from custodial interrogation without counsel." United States v. Tyler , 592 F.2d 261 (5th Cir. 1979). *Page 239

1985Twyman v. State , 293 Ala. 75 , 300 So.2d 124 (1974); Cashin v. State , 428 So.2d 179 (Ala.Crim.App. 1982); Dingler v. State , 408 So.2d 527 (Ala.Crim.App.), writ quashed, 408 So.2d 530 (Ala. 1981); Fields v. State , 339 So.2d 1088 (Ala.Crim.App. 1976); Ireland v. State , supra. In Twyman v. State , supra, the Alabama Supreme Court held a guilty plea to be intelligently and voluntarily entered when the Ireland form is executed and signed by a defendant and acknowledged by the signature of the defense counsel and circuit judge, provided there is other evidence in the record supporting that fact

1985Twyman v. State , 293 Ala. 75 , 300 So.2d 124 (1974); Cashin v. State , 428 So.2d 179 (Ala.Crim.App. 1982); Dingler v. State , 408 So.2d 527 (Ala.Crim.App.), writ quashed, 408 So.2d 530 (Ala. 1981); Fields v. State , 339 So.2d 1088 (Ala.Crim.App. 1976); Ireland v. State , supra. In Twyman v. State , supra, the Alabama Supreme Court held a guilty plea to be intelligently and voluntarily entered when the Ireland form is executed and signed by a defendant and acknowledged by the signature of the defense counsel and circuit judge, provided there is other evidence in the record supporting that fact

1985Twyman v. State , 293 Ala. 75 , 300 So.2d 124 (1974); Cashin v. State , 428 So.2d 179 (Ala.Crim.App. 1982); Dingler v. State , 408 So.2d 527 (Ala.Crim.App.), writ quashed, 408 So.2d 530 (Ala. 1981); Fields v. State , 339 So.2d 1088 (Ala.Crim.App. 1976); Ireland v. State , supra. In Twyman v. State , supra, the Alabama Supreme Court held a guilty plea to be intelligently and voluntarily entered when the Ireland form is executed and signed by a defendant and acknowledged by the signature of the defense counsel and circuit judge, provided there is other evidence in the record supporting that fact

1985Twyman v. State , 293 Ala. 75 , 300 So.2d 124 (1974); Cashin v. State , 428 So.2d 179 (Ala.Crim.App. 1982); Dingler v. State , 408 So.2d 527 (Ala.Crim.App.), writ quashed, 408 So.2d 530 (Ala. 1981); Fields v. State , 339 So.2d 1088 (Ala.Crim.App. 1976); Ireland v. State , supra. In Twyman v. State , supra, the Alabama Supreme Court held a guilty plea to be intelligently and voluntarily entered when the Ireland form is executed and signed by a defendant and acknowledged by the signature of the defense counsel and circuit judge, provided there is other evidence in the record supporting that fact

1985Twyman v. State , 293 Ala. 75 , 300 So.2d 124 (1974); Cashin v. State , 428 So.2d 179 (Ala.Crim.App. 1982); Dingler v. State , 408 So.2d 527 (Ala.Crim.App.), writ quashed, 408 So.2d 530 (Ala. 1981); Fields v. State , 339 So.2d 1088 (Ala.Crim.App. 1976); Ireland v. State , supra. In Twyman v. State , supra, the Alabama Supreme Court held a guilty plea to be intelligently and voluntarily entered when the Ireland form is executed and signed by a defendant and acknowledged by the signature of the defense counsel and circuit judge, provided there is other evidence in the record supporting that fact

1985McCormick observes the following: "`[T]he courts are stricter in applying their standards of relevancy when the ultimate purpose of the state is to prove identity, or the doing by the accused of the criminal act charged than they are when the evidence is offered on the ultimate issue of knowledge. . . .'" This strict test of similarity has long been held to mean that the two offenses have been committed by some "novel or extraordinary means or in a peculiar or unusual manner." Wilder v. State , 30 Ala. App. 107 , 109 , 1 So.2d 317 , 319 (1941).

1985McCormick observes the following: "`[T]he courts are stricter in applying their standards of relevancy when the ultimate purpose of the state is to prove identity, or the doing by the accused of the criminal act charged than they are when the evidence is offered on the ultimate issue of knowledge. . . .'" This strict test of similarity has long been held to mean that the two offenses have been committed by some "novel or extraordinary means or in a peculiar or unusual manner." Wilder v. State , 30 Ala. App. 107 , 109 , 1 So.2d 317 , 319 (1941).

1985Twyman v. State , 293 Ala. 75 , 300 So.2d 124 (1974); Cashin v. State , 428 So.2d 179 (Ala.Crim.App. 1982); Dingler v. State , 408 So.2d 527 (Ala.Crim.App.), writ quashed, 408 So.2d 530 (Ala. 1981); Fields v. State , 339 So.2d 1088 (Ala.Crim.App. 1976); Ireland v. State , supra. In Twyman v. State , supra, the Alabama Supreme Court held a guilty plea to be intelligently and voluntarily entered when the Ireland form is executed and signed by a defendant and acknowledged by the signature of the defense counsel and circuit judge, provided there is other evidence in the record supporting that fact