Pressley v. Alabama

Background

A person in Alabama filed a motion to proceed in forma pauperis and asked the Supreme Court to review a decision from the Alabama Court of Criminal Appeals. The Court granted the in forma pauperis motion and the petition, vacated the lower court’s judgment, and remanded the case to the Alabama court for further consideration in light of Montgomery v. Louisiana. The Court noted that it had held this petition and many similar cases while Montgomery was pending.

Reasoning

The narrow question was whether the petitioner’s claim should be reconsidered because of the Court’s decision in Montgomery v. Louisiana. The Supreme Court did not decide whether the petitioner is entitled to retroactive relief. Instead, it vacated the judgment and sent the case back so the state court can apply Montgomery and decide whether relief is proper. The Court’s order expressly did not address procedural or factual barriers to relief, such as whether an independent state law ground blocks relief, whether the petitioner waived or forfeited claims (for example by a plea agreement), or whether the sentence actually counts as a mandatory life‑without‑parole sentence.

Real world impact

The Alabama court must now reexamine the case using Montgomery’s guidance. This may lead to further litigation about whether a sentence qualifies for relief, and whether state procedures or plea deals prevent relief. The Supreme Court’s action is not a final decision on the merits; it simply requires the lower court to reconsider under the new Supreme Court rule.

Dissents or concurrances

Justice Thomas, joined by Justice Alito, wrote a concurrence emphasizing that the GVR does not signal any view on whether the petitioner actually deserves relief.