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Alabama Supreme Court Holds Miller Entitled to Retroactivity

On August 25, 2017, the Alabama Supreme Court held the decision in Miller v. Alabama, 132 S.Ct. 2455 (2012), which prohibits mandatory life-without-parole sentences for juvenile offenders, was “a substantive rule that is retroactive in cases on collateral review.”

That ruling came in a petition filed by prisoner Jimmy Williams, Jr., who was convicted of capital murder committed during a robbery. The crime occurred in 1975 when Williams was 15 years old; he was sentenced to the only possible sentence at the time, life without parole.

After Miller was decided, which held that a mandatory sentence of life imprisonment without the possibility of parole for a juvenile defendant violates the Eighth Amendment’s prohibition on cruel and unusual punishment, Williams sought relief from his sentence. The circuit court, the Court of Criminal Appeals and the Alabama Supreme Court all held that Williams was not entitled to resentencing, as his case was final before Miller was decided.

Williams then sought review in the U.S. Supreme Court. While his petition was pending, the high court held in Montgomery v. Louisiana, 136 S.Ct. 718 (2016) [PLN, March 2016, p.48] that Miller was entitled to retroactive application. As a result, the decision in Williams’ case was vacated and the case remanded. The Alabama Supreme Court then followed the U.S. Supreme Court’s direction and applied Miller retroactively.

Consequently, Williams’ judgment was vacated and remanded to the circuit court for resentencing. See: Ex Parte Jimmy Williams, Jr., 2017 Ala. LEXIS 73 (Ala. 2017). 


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Related legal case

Ex Parte Jimmy Williams, Jr.