Friday, November 15, 2013

Collins v. Youngblood case brief

Collins v. Youngblood case brief summary
497 U.S. 37 (1990)


CASE SYNOPSIS
Petitioner appealed an order of the United States Court of Appeals for the Fifth Circuit, which reversed a lower court finding that retroactive application of Tex. Code Crim. Proc. Ann. Article 37.10(b) (Supp. 1990) to respondent prisoner did not violate U.S. Constitutional Article I, § 10.

CASE FACTS
Respondent, an improperly sentenced prisoner, applied for writ of habeas corpus arguing that precedent required the court to find that the sentence was void and to set it aside. Before respondent's habeas petition was considered, a new statute became effective, Tex. Code Crim. Proc. Ann. Article 37.10(b) (Supp. 1990), which allowed an appellate court to reform an improper verdict. The appellate court retroactively applied the statute and reformed the verdict. Respondent then argued that the retroactive application violated U.S. Constitutional Article I, § 10. The trial court found no such violation, but the appellate court reversed.

DISCUSSION
  • The United States Supreme Court reversed, holding that the statute did not violate U.S. Constitutional Article I, § 10 because it did not punish a previously committed act as a crime, make a punishment more burdensome, nor deprive respondent of any defense available according to the law at the time the act was committed.

CONCLUSION
The Court reversed and held that retroactive application of a statute allowing judicial reformation of an improper verdict did not violate the Ex Post Facto Clause because it did not make respondent prisoner's punishment more burdensome.

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