The prosecutor subsequently filed motions to recuse Todd in all future cases in which he was involved. Todd denied the motions and, on appeal, asserted that the motions had been filed in retaliation for her decision striking down the death penalty. “Historically, judges in Alabama who made unfavorable rulings against the interests of the power structure were threatened, ostracized and made subject of personal and political retaliation,” she wrote in opposing the recusal appeal. “The methods employed in these petitions amount to tactical relics of dark days past.”