Duke v. Alabama

Background

A person serving what he says is a mandatory life without parole sentence asked the Alabama Court of Criminal Appeals to have his case reconsidered after the Supreme Court decided Montgomery v. Louisiana. The petitioner also sought permission to proceed without paying fees, and the Supreme Court held the petition pending Montgomery before acting. The Court then granted leave to proceed in forma pauperis and agreed to review the case.

Reasoning

The core question was whether the petitioner is entitled to retroactive relief under Montgomery. Rather than decide the merits, the Supreme Court vacated the Alabama court’s judgment and sent the case back for further consideration in light of Montgomery. The Court expressly did not rule on whether the petitioner actually deserves relief or whether any state-law obstacles prevent relief.

Real world impact

On remand, the Alabama Court of Criminal Appeals must reconsider the petitioner’s claims under Montgomery. The Supreme Court’s order does not settle the main legal questions and leaves it open whether state procedural rules or plea agreements bar relief. The outcome will depend on the state court’s further review of whether the petitioner forfeited or waived claims and whether the sentence qualifies as a mandatory life-without-parole term.

Dissents or concurrances

Justice Thomas, joined by Justice Alito, wrote separately to emphasize that the Supreme Court’s action should not be read as deciding entitlement to relief and to list procedural and factual questions the state court should address.