Thompson v. Roy

2016-03-07
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Headline: Grant, vacate, and remand order sends the case back to the Eighth Circuit to reconsider retroactive relief in light of Montgomery, leaving life-without-parole and waiver questions unresolved.

Holding:

Real World Impact:
  • Sends the case back to the Eighth Circuit for reconsideration under Montgomery.
  • Does not grant immediate relief; entitlement questions remain undecided.
  • Leaves open issues about state-law defenses, plea waivers, and sentence classification.
Topics: retroactive relief, life-without-parole sentences, appeals and remands, plea agreement waivers

Summary

Background

A person asked the Supreme Court to review a decision by the United States Court of Appeals for the Eighth Circuit. That person also asked permission to proceed without paying court fees, and the Court granted that request and agreed to consider the petition.

Reasoning

The Court explained it had held this petition, along with many others, while it decided Montgomery v. Louisiana. After Montgomery, the Court granted review, vacated the appeals-court judgment, and sent the case back to the Eighth Circuit to reconsider in light of Montgomery. The Court’s short order did not decide whether the person is entitled to retroactive relief.

Real world impact

The appeals court must now reexamine the case using the Supreme Court’s Montgomery decision. The Supreme Court’s action does not itself give the person any relief and leaves open important questions about state-law defenses, whether any waiver in a plea agreement bars relief, and whether the sentence actually qualifies as a mandatory life-without-parole term. Because the Supreme Court did not resolve those issues, additional proceedings in the lower courts are likely.

Dissents or concurrances

Justice Thomas, joined by Justice Alito, wrote separately to emphasize that the grant-vacate-remand order should not be read as deciding entitlement to relief and warned that the order does not resolve state-law bars, plea waivers, or sentence classification.

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