Williams v. State
183 So. 3d 220
Ala.2015Background
- Jimmy Williams Jr. was convicted in 2000 of capital murder for an offense committed at age 15 and was mandatorily sentenced to life without parole under Alabama law in effect then; his conviction became final in 2002.
- In 2012 the U.S. Supreme Court decided Miller v. Alabama, holding mandatory life-without-parole for juvenile homicide offenders violates the Eighth Amendment and requires individualized sentencing consideration of youth-related factors.
- In 2013 Williams filed a Rule 32 petition seeking resentencing under Miller; the State moved to dismiss arguing Miller is not retroactive to cases already final.
- The circuit court dismissed the petition; the Alabama Court of Criminal Appeals affirmed, holding Miller announced a new rule that is not retroactive on collateral review.
- The Alabama Supreme Court granted certiorari to decide whether Miller applies retroactively and therefore whether Williams is entitled to resentencing; the Court affirms the Court of Criminal Appeals.
Issues
| Issue | Plaintiff's Argument (Williams) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether Miller announced a new rule | Miller created a constitutional rule requiring resentencing for juveniles sentenced mandatorily to LWOP | Miller is a new rule but should not be applied retroactively | Court: Miller is a new rule (agreed) |
| Whether Miller is substantive (thus retroactive) or procedural | Miller substantively changed sentencing by removing mandatory LWOP for juveniles — so it is retroactive like Atkins | Miller is procedural: it changes the sentencing method but does not categorically forbid LWOP for juveniles, so not retroactive | Court: Miller is procedural, not substantive; not retroactive |
| Whether Miller is a ‘‘watershed’’ procedural rule (Teague exception) | Miller is fundamental to fairness and accuracy of sentencing for juveniles | Miller is not a watershed rule; it does not create a previously unrecognized bedrock procedure like Gideon | Court: Miller is not a watershed rule; Teague exception not met |
| Whether Rule 32.1(b)/(c) relief is warranted (illegal sentence / lack of jurisdiction) | Because Miller rendered mandatory LWOP unconstitutional, Williams’s sentence is illegal and the trial court lacked jurisdiction | At sentencing Williams’s sentence was lawful under the law at the time; a later change does not make the prior sentence illegal | Court: No relief under Rule 32.1(b) or (c); sentence was legal when imposed |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory LWOP for juvenile homicide offenders violates Eighth Amendment; individualized sentencing required)
- Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for offenders under 18)
- Graham v. Florida, 560 U.S. 48 (2010) (LWOP for non-homicide juvenile offenders unconstitutional)
- Atkins v. Virginia, 536 U.S. 304 (2002) (death penalty unconstitutional for intellectually disabled defendants)
- Teague v. Lane, 489 U.S. 288 (1989) (framework for retroactivity of new rules on collateral review)
- Schriro v. Summerlin, 542 U.S. 348 (2004) (distinguishing substantive vs. procedural new rules for retroactivity)
- Whorton v. Bockting, 549 U.S. 406 (2007) (new vs. old rule distinction; watershed exception discussion)
- Ring v. Arizona, 536 U.S. 584 (2002) (procedural change in death-eligibility factfinding not retroactive)
- Gideon v. Wainwright, 372 U.S. 335 (1963) (right to counsel as archetypal watershed rule)
- Padilla v. Kentucky, 559 U.S. 356 (2010) (new ineffective-assistance rule later held not retroactive in Chaidez)
- Chaidez v. United States, 568 U.S. 342 (2013) (Padilla rule held nonretroactive)
- Tyler v. Cain, 533 U.S. 656 (2001) (requirements for relying on single-case retroactivity)