Black v. Alabama

Background

A person sentenced in Alabama asked the Supreme Court to review a state appellate decision. The Court allowed the person to proceed in forma pauperis (without paying fees), granted the petition for review, vacated the judgment below, and sent the case back to the Alabama Court of Criminal Appeals for further consideration in light of Montgomery v. Louisiana (2016).

Reasoning

The core question was whether the person’s claim is entitled to retroactive relief under Montgomery. The Supreme Court did not answer that question here. Instead, the Court held the petition pending the Montgomery decision, and then, after Montgomery, it vacated the lower court’s judgment and remanded the case for the state court to reconsider in light of Montgomery. The Supreme Court made clear its disposition is limited and does not decide whether the person actually deserves relief.

Real world impact

On remand, the Alabama court must re-evaluate the conviction or sentence using Montgomery as guidance. The Supreme Court’s action does not resolve important practical barriers that could block relief, such as state procedural rules, whether the person waived rights by a plea agreement, or whether the sentence was truly a mandatory life-without-parole term. Because this is a vacate-and-remand order rather than a final merits ruling, the outcome could change after the state court’s further consideration.

Dissents or concurrances

Justice Thomas, joined by Justice Alito, wrote separately to emphasize the narrowness of the Court’s action and to list issues the lower courts should address on remand. He warned the Court did not address state procedural bars, forfeiture or waiver issues, plea agreements, or whether the sentence qualifies as mandatory life without parole.