Hogan v. Alabama

Background

A person convicted in Alabama asked the Supreme Court to review a decision from the Court of Criminal Appeals of Alabama and moved to proceed without paying court fees. The Supreme Court granted the motion to proceed without fees, granted the petition for review, vacated the lower court’s judgment, and sent the case back to the Alabama court for further consideration in light of Montgomery v. Louisiana (2016).

Reasoning

The Court did not decide whether the person is entitled to retroactive relief under Montgomery. Instead, the Court held this petition pending Montgomery and then vacated and remanded the lower-court judgment so the Alabama court can reconsider the case under Montgomery’s guidance. The majority’s order does not resolve the merits or say who ultimately wins.

Real world impact

The ruling sends this and similar cases back to lower courts to reevaluate whether prisoners are entitled to relief under Montgomery. It does not itself grant relief and leaves open questions that the lower courts must address, such as whether state-law procedural bars apply or whether the original sentence qualifies as a mandatory life-without-parole sentence.

Dissents or concurrances

Justice Thomas, joined by Justice Alito, wrote a brief concurrence emphasizing that the Court’s order does not express any view about entitlement to relief and warning that lower courts should consider possible state-law bars, forfeiture or waiver, and whether the sentence was truly mandatory life without parole.