Madden v. State

In August 1982, Joseph Wayne Madden pleaded guilty to three counts of receiving stolen property in the first degree. In 2005, Madden filed a Rule 32, Ala. R.Crim. P., petition, contending that the indictments upon which his guilty-plea convictions were based were void because the indictments omitted an essential element of the offense — that he had "intentionally" received the stolen property. Madden contended that his claims were jurisdictional and that they could therefore be raised at any time.

The trial court denied Madden's petition, and Madden appealed. The Court of Criminal Appeals…