McWilliams v. Alabama
Headline: Court sends an Alabama inmate’s case back to state court for reconsideration under a recent ruling, vacating the lower judgment but not deciding whether the inmate will get relief.
Holding: The Court granted review, set aside the Alabama court’s judgment, and sent the case back for reconsideration under Montgomery without deciding entitlement to relief.
- Sends the Alabama case back for reconsideration under Montgomery.
- Does not grant or deny relief; outcome remains open.
- Alerts courts to consider plea waivers, forfeiture, or state-law bars.
Summary
Background
An Alabama person who challenged a sentence asked the Supreme Court to review a judgment from the Court of Criminal Appeals of Alabama. The person also moved to proceed without paying court fees. The Supreme Court agreed to hear the petition, set aside the lower court’s judgment, and sent the case back to the Alabama court for further consideration in light of the Court’s recent decision in Montgomery v. Louisiana.
Reasoning
The central question was whether the person was entitled to retroactive relief under the principles announced in Montgomery. Rather than decide that substantive question, the Supreme Court held this petition pending Montgomery and then vacated and remanded so the state court can reconsider the case in light of Montgomery. The Court expressly did not determine whether the person actually deserves relief.
Real world impact
Because this order only sends the case back without ruling on the merits, the outcome remains open. The Alabama court must review the case under Montgomery, and it may consider procedural or state-law limits before granting relief. The Supreme Court’s action does not itself restore or change the sentence; it simply requires further review.
Dissents or concurrances
Justice Thomas, joined by Justice Alito, wrote a concurrence emphasizing that the Court’s decision to vacate and remand does not express any view about whether the person is entitled to relief. He warned that the state court should consider whether state-law grounds, plea waivers, forfeiture, or whether the sentence actually qualifies as a mandatory life without parole sentence might bar relief.
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