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State v. Rutledge
Citations: 184 So. 3d 462; 2014 Ala. Crim. App. LEXIS 61; 2014 WL 4387836Docket: CR-13-0874
Court: Court of Criminal Appeals of Alabama; September 5, 2014; Alabama; State Appellate Court
The State of Alabama appeals the circuit court's decision to grant Tommy Lee Rutledge postconviction relief under Rule 32, Ala. R.Crim. P., challenging his life imprisonment sentence without parole for a 1995 capital murder conviction. Rutledge, who was 17 years old at the time of the offense, argued that his sentence is unconstitutional based on the U.S. Supreme Court's ruling in Miller v. Alabama, which deemed mandatory life sentences without parole for juveniles unconstitutional. The State filed a motion to dismiss Rutledge’s petition, asserting that his claims were precluded by Rules 32.2(a)(3) and (5) and that Miller does not apply retroactively in collateral review cases. Rutledge countered that Miller should apply retroactively and that his petition was not procedurally barred. The circuit court granted Rutledge a new sentencing hearing, leading to the State's appeal. The key legal issue is the retroactivity of Miller's ruling. The appellate court, using a de novo review standard, examined the arguments. It cited Williams v. State, which concluded that claims challenging mandatory life sentences for juveniles under Miller are not valid grounds for postconviction relief under Rule 32.1(b) or (c), but rather under Rule 32.1(a). Moreover, the court reaffirmed that Miller does not apply retroactively. Consequently, the appellate court reversed the circuit court's decision, determining that Rutledge was not entitled to a new sentencing hearing based on the precedents established in Williams. The case is remanded for proceedings consistent with this ruling. The judges concurred with the reversal. Notably, the State acknowledged Rutledge's actual age of 17 at the time of the offense, correcting a prior misstatement.