Foster v. Alabama

Background

A person convicted in Alabama challenged a sentence that may be a mandatory life without parole. The individual asked the Supreme Court to review the Alabama Court of Criminal Appeals’ decision and also asked to proceed without paying fees. The Court held the petition while it decided Montgomery v. Louisiana and now acted on this case after that decision.

Reasoning

The Court granted the fee request and allowed the petition for review, then vacated (erased) the lower court’s judgment and sent the case back to the Alabama Court of Criminal Appeals for further consideration in light of Montgomery v. Louisiana. The opinion itself does not resolve whether the person is entitled to any retroactive relief under Montgomery; it simply requires the state court to re-evaluate the case applying that new guidance.

Real world impact

The immediate effect is procedural: the Alabama appeals court must reconsider the conviction or sentence under the Supreme Court’s Montgomery rule. The ruling is not a final decision on whether relief should be granted. Whether the person ultimately gets relief may depend on state-law issues, any plea agreements, or whether the original sentence truly qualified as a mandatory life-without-parole sentence.

Dissents or concurrances

Justice Thomas, joined by Justice Alito, wrote separately to stress that the Court’s action does not signal any view on entitlement to relief and listed issues state courts should consider on remand, like procedural bars, forfeiture, plea waivers, and whether the sentence was truly mandatory.