In Ward v. State, No. CR-98-0800, 2000 WL 127207 (Ala. Crim. App., Feb. 4, 2000), the defendant was convicted of first degree murder for the suffocation of his four-month-old son. An autopsy revealed that the victim had suffered multiple fractures to the arms and ribs and damage to his toenails and fingernails, indications of instances of torture or extreme abuse. Id. The victim had also suffered a spiral fracture of his right arm the day before his death. Id. The causes of death were established as multiple blunt force injuries and suffocation. Id. On the jury's recommendation, the trial court imposed the death sentence based on the aggravating circumstance that the murder qualified as heinous, atrocious and cruel. The Alabama Court of Criminal Appeals affirmed the conviction and sentence.