Collins v. Youngblood
497 U.S. 37 (1990)
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Rule of Law:
A law violates the Ex Post Facto Clause only if it is a penal statute that retroactively alters the definition of a crime or increases the punishment for a criminal act. A retroactive change in law is not an ex post facto violation if it is merely procedural and does not deprive the defendant of a defense or fall within the historical categories of forbidden laws.
Facts:
- Carroll Youngblood was convicted of aggravated sexual abuse in Texas.
- The jury sentenced him to life imprisonment and imposed a $10,000 fine.
- At the time of Youngblood's crime, Texas law did not authorize a fine in addition to a prison term for his offense.
- Under existing Texas case law at the time of the offense and conviction (Bogany v. State), a verdict with an unauthorized punishment was considered void and entitled the defendant to a new trial.
- After Youngblood's conviction, the Texas legislature enacted Article 37.10(b), a statute allowing appellate courts to reform improper verdicts by simply deleting the unauthorized portion of the punishment.
Procedural Posture:
- Carroll Youngblood was convicted in a Texas state trial court.
- His conviction and sentence were affirmed by the Texas Court of Criminal Appeals on direct appeal.
- Youngblood filed a state habeas corpus petition in the State District Court, arguing his sentence was void under the Bogany decision.
- The State District Court recommended granting the writ.
- Before the Texas Court of Criminal Appeals could act on the recommendation, a new state statute (Art. 37.10(b)) was passed.
- The Texas Court of Criminal Appeals, as the highest criminal court in the state, applied the new statute to reform Youngblood's sentence by deleting the fine and denied his habeas petition.
- Youngblood filed a federal habeas corpus petition in the U.S. District Court for the Eastern District of Texas, which denied his ex post facto claim.
- Youngblood, as appellant, appealed to the U.S. Court of Appeals for the Fifth Circuit, which reversed the District Court, finding an ex post facto violation.
- The State of Texas, as petitioner, was granted certiorari by the U.S. Supreme Court.
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Issue:
Does the retroactive application of a state statute, which permits an appellate court to reform an improper jury verdict by deleting an unauthorized punishment rather than ordering a new trial, violate the Ex Post Facto Clause of the U.S. Constitution?
Opinions:
Majority - Chief Justice Rehnquist
No. The retroactive application of the Texas statute does not violate the Ex Post Facto Clause because it does not fall within the categories of laws prohibited by the clause. The Clause prohibits laws that (1) criminalize an act that was innocent when done, (2) aggravate a crime, (3) increase the punishment, or (4) alter the rules of evidence to require less proof for a conviction. The Texas statute is a procedural change that does not alter the definition of Youngblood's crime, increase his punishment (it actually decreased it by removing the fine), or deprive him of a defense related to the elements of the crime. The Court explicitly overruled Kring v. Missouri and Thompson v. Utah to the extent they suggested that any retroactive procedural change that alters a defendant's situation to their disadvantage or removes a 'substantial protection' is an ex post facto violation, clarifying that the prohibition is limited to the four historical Calder v. Bull categories.
Concurring - Justice Stevens
No. The Texas statute does not violate the Ex Post Facto Clause, but the majority's decision to overrule prior precedent is unnecessary. The conclusion is consistent with existing cases, including Kring and Thompson, because the right to a new trial based on a sentencing error is not a 'substantial protection' that existed at the time of the offense. A procedural protection is 'substantial' only if it affects the means by which a valid conviction or sentence may be imposed. Here, Youngblood had already been validly convicted and sentenced (apart from the erroneous fine). The new law simply altered a postconviction remedy for correcting an error, rather than affecting his rights at trial or sentencing, and thus did not impair any substantial right he possessed when the crime was committed.
Analysis:
This decision significantly narrowed the scope of the Ex Post Facto Clause's application to procedural laws. By explicitly rejecting the broader 'substantial protections' or 'disadvantage' tests from Kring and Thompson, the Court returned to the stricter, originalist interpretation from Calder v. Bull. This makes it much more difficult for criminal defendants to challenge retroactive procedural changes unless those changes directly alter the legal definition of the crime, the available punishment, or the evidentiary standards for conviction. The ruling gives state legislatures more flexibility to reform criminal procedures and apply those reforms to pending cases without constitutional challenge.
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