Bell v. State

Appellant, Alonzo Bell, was indicted by a one-count indictment charging that he intentionally murdered Maxine Bush in violation of § 13A-6-2, Code of Alabama 1975. He was convicted of murder and sentenced to a term of twenty years' imprisonment.

We need only address Bell's first contention of error. He argues that the trial court erred in instructing the jury on "universal malice" murder, defined by § 13A-6-2 (a)(2), because the indictment only alleged that he acted intentionally in causing the victim's death (§ 13A-6-2 (a)(1)). The Alabama Supreme Court in Ex parte Washington, 448 So.2d 404…