(MOBILE, Ala.) - A Mobile County man convicted of killing his wife and 2-year-old son in 2008 is facing the death penalty again after the Alabama Court of Criminal Appeals overturned a lower court’s decision that had spared him from execution.
Michael Bragg Woolf was convicted of murdering his wife and son in March 2008. Photo courtesy of the Alabama Department of Corrections.
In its Nov. 6 opinion, the Alabama Court of Criminal Appeals reviewed whether Michael Bragg Woolf met the legal definition of intellectual disability, which would prohibit the state from executing him under the Eighth Amendment.
Woolf was convicted in Nov. 2010 of two counts of capital murder in the shooting deaths of his wife, Angel Marie Woolf, and their son, Charles Ayden Woolf, at the family’s Mobile County home on March 5, 2008. An 11-1 jury vote recommended the death penalty, which the trial judge imposed in 2011.
According to testimony detailed in Woolf’s original appeal, the couple had been experiencing marital problems, including questions Woolf had raised about whether he was Ayden’s biological father. In February 2008, just weeks before the shootings, the family visited Mobile testing laboratory Resultz Corp. for a paternity test. Woolf returned to the laboratory on March 3, stating he was having trouble understanding the results.
Shortly after midnight on March 5, Woolf called 911 and reported that he had killed his family. Police responding to the residence discovered Woolf’s wife and son dead from gunshot wounds. Investigators also recovered a .38-caliber revolver from the living room.
Woolf later testified that the gun went off during an argument with his wife, hitting Ayden by accident before he shot Angel. The jury rejected that account.
After unsuccessfully appealing his convictions and death sentence, Woolf filed another challenge in 2017. During an August 2024 hearing, psychologists testified about Woolf’s intellectual abilities and reviewed records of IQ testing dating back to his childhood.
The Mobile judge agreed that Woolf was intellectually disabled, meaning the state could no longer execute him. His death sentence was set aside and replaced with life imprisonment without the possibility of parole.
Under a 2002 U.S. Supreme Court ruling, Atkins v. Virginia, executing a person with an intellectual disability violates the Eighth Amendment’s prohibition against cruel and unusual punishment. Later rulings, including Hall v. Florida in 2014, said courts can’t rely on an IQ cutoff alone. Under Alabama law, a defendant has to show significantly below-average intellectual functioning, real deficits in everyday adaptive skills, and that both showed up before age 18.
The State’s appeal came down to nine IQ tests Woolf took over his lifetime. Not one came in below 74. The State argued that the lower court had improperly discounted several of Woolf’s higher childhood IQ scores while relying on lower scores to support its finding of intellectual disability.
The appeals court agreed. The circuit judge had tossed out several higher scores because the raw testing data was missing, but the lower scores he relied on had the same problem. The judges also rejected Woolf’s claims concerning ineffective assistance of trial counsel.
The case now returns to Mobile Circuit Court with instructions to reinstate Woolf’s death sentence. The November 6 decision does not establish an execution date.
To add to or correct any information in this report, please contact me at neeli.f@lead4earth.org.
0
2
Comments