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Collins v. Youngblood

    Brief Fact Summary.

    Defendant was convicted of aggravated sexual abuse in Texas state court. The state court of appeals affirmed. The Texas district court granted Defendant’s writ of habeas corpus. The Texas legislature enacted a law to allow an appellate court to reform an improper verdict that assessed a punishment not authorized by law. Relying on the new statute, the appellate court reformed Defendant’s conviction by removing the $10,000 fine from his sentence and denied his request for a new trial. Defendant then filed a petition for a writ of habeas corpus in U.S. District Court claiming Texas’ retroactive law violated the Ex Post Facto Clause. The petition was denied by the district court and the court of appeals reversed. The U.S. Supreme Court granted certiorari to review.

    Synopsis of Rule of Law.

    The Ex Post Facto Clause does not bar reformation of a sentence imposed against an offender after it has been handed down.

    Facts.

    Carroll Youngblood (Defendant) was convicted in a Texas court of aggravated sexual abuse and was sentenced to life imprisonment and a fine of $10,000. After his conviction was affirmed by the Texas Court of Criminal Appeals, Defendant filed a petition for a writ of habeas corpus in Texas district court, arguing that the Texas Code of Criminal Procedure did not authorize a fine in addition to a term of imprisonment for his offense and thus his conviction was void. The district court granted Defendant’s writ. Before the writ could be considered by the Texas Court of Criminal Appeals, the Texas Legislature enacted a law to allow an appellate court to reform an improper verdict that assessed a punishment not authorized by law. Relying on the new statute, the appellate court reformed Defendant’s conviction by removing the $10,000 fine from his sentence and denied his request for a new trial. Defendant then filed a petition for a writ of habeas corpus in U.S. District Court claiming Texas’ retroactive law violated the Ex Post Facto Clause. The petition was denied by the district court and the court of appeals reversed. The U.S. Supreme Court granted certiorari to review.

    Issue.

    Whether the Ex Post Facto Clause bars reformation of a sentence imposed against an offender after it has been handed down.

    Held.

    No. The court of appeals’ ruling is reversed. The Ex Post Facto Clause does not bar reformation of a sentence imposed against an offender after it has been handed down.

    Discussion.

    The Supreme Court has long held that the constitutional prohibition on ex post facto laws applies only to penal statutes which disadvantage the offender affected by them. In Calder v. Bull, 3 U.S. 386 (1798), Justice Chase articulated those legislative acts which, in his view, implicate the concerns of the Ex Post Facto Clause. Those acts include: (1) every law that makes an action criminal that was legal when committed; (2) every law that aggravates a crime, or makes it greater than it was, when committed; (3) every law that changes the punishment, and inflicts a greater punishment, than was stated in the law at the time the act was committed; and (4) every law that alters the legal rules of evidence, and changes the testimony required to convict the offender. Since Justice Chase’s statement, there has been extensive commentary about what qualifies, and what does not qualify, as an act barred by the Ex Post Facto Clause. The new Texas statute is a procedural change that allows reformation of improper verdict. It does not alter the definition of the crime of aggravated sexual abuse nor increases the punishment for which he is eligible as a result of his conviction. Nevertheless, Defendant argues that his conviction must be reversed because the new Texas law contravenes the Ex Post Facto Clause if it deprives the accused of a “substantial protection” existing at the time of the crime. The Court has examined several cases that have described changes as “procedural” which, even though they disadvantage the accused, do not violate the Ex Post Facto Clause. Those cases do not explicitly define what they mean by “procedural.” However, it is logical to think that the term refers to changes in the procedures by which criminal cases are adjudicated. In Duncan v. Missouri, 152 U.S. 377 (1894), the Court re-articulated Justice Chase’s four categories and further stated that “…the prescribing of different modes or procedure and the abolition of courts and creation of new ones, leaving untouched all the substantial protections with which the existing law surrounds the person accused of crime…” are not considered to be barred by the Ex Post Facto Clause. The cases cited by Defendant in support of his argument, Kring v. Missouri, 107 U.S. 221 (1883) and Thompson v. Utah, 170 U.S. 343 (1898), do not fit the specific analytical framework created and supported by precedent. In Thompson, the accused was charged in Utah, when it was still a Territory, with grand larceny. He was tried by 12-person jury and convicted. Thereafter, Utah became a State and required that noncapital juries would consist of eight individuals. The Court reversed Thompson’s conviction and reasoned that the right to jury trial was clearly “substantial” and the Ex Post Facto Clause prevented the State from taking away that right from Thompson when it became a state. However, the right to a jury trial is a right provided for by the Sixth Amendment and has nothing to do with the definition of crimes, defenses, or punishments, which is the concern of the Ex Post Facto Clause. To the extent that Thompson rested on the Ex Post Facto Clause, it is overruled. Here, the Texas law allowing for reformation of improper verdicts does not meet any of the four categories articulated in Calder v. Bull and is thus not prohibited by the Ex Post Facto Clause.


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