Barnes v. Alabama

Background

An individual whose case reached the Court from the Court of Criminal Appeals of Alabama asked the Court to review his conviction and sentence and to proceed without payment of court fees. The Supreme Court granted the request for review, then vacated the lower court’s judgment and returned the case for the state court to reconsider in light of the Court’s recent Montgomery decision.

Reasoning

The Court’s action was procedural: it sent the case back to the Alabama appeals court to apply Montgomery and to decide whether the petitioner is entitled to retroactive relief. The opinion does not resolve on the merits whether the person gets relief. Justice Thomas emphasized that vacating and remanding does not decide entitlement and listed issues for the state court to consider, including whether state-law grounds block relief, whether the person forfeited or waived claims (for example, by a plea agreement), and whether the sentence actually qualifies as a mandatory life-without-parole sentence.

Real world impact

The Alabama appeals court must now reexamine the case under the Montgomery ruling and decide if the petitioner should receive retroactive relief. The Supreme Court’s disposition is not a final determination that the petitioner wins relief; it only requires reconsideration. Similar cases involving life-without-parole sentences may be sent back to state courts for the same review.

Dissents or concurrances

Several Justices wrote brief concurrences. Justices Thomas and Alito joined a concurrence stressing limits on what the remand decides, and Justices Sotomayor and Ginsburg noted their agreement with granting, vacating, and remanding.