Ingram v. Alabama

Background

A person convicted in Alabama asked the state appellate court to address their sentence and then sought review from the Supreme Court. The person also moved to proceed without paying court fees, and the Supreme Court granted that motion and the petition for review. The Court had held this petition pending resolution of a related Supreme Court decision, and it later acted after that decision issued.

Reasoning

The Supreme Court granted the petition, vacated the judgment of the Alabama Court of Criminal Appeals, and sent the case back for further consideration in light of Montgomery v. Louisiana. The Court’s order to hold, vacate, and remand did not decide whether the person is entitled to any retroactive relief from their sentence. The opinion and the concurring note emphasize that the narrow disposition leaves factual and procedural questions for the state court to address.

Real world impact

On remand, the Alabama court must re-evaluate the case under the guidance called for by Montgomery, but the Supreme Court’s order does not itself change the sentence. The order does not resolve whether state-law rules or other procedural bars prevent relief. It also does not decide whether the person forfeited or waived claims—such as by entering a plea agreement—or whether the original sentence qualifies as a mandatory life-without-parole sentence.

Dissents or concurrances

Justice Thomas, joined by Justice Alito, wrote a concurrence clarifying that the Court’s action is limited and should not be read as speaking to the merits of the petitioner’s entitlement to relief.