Supreme Court of Alabama

Ex Parte Reginald Tyrone Lightfoot. (in Re Reginald Tyrone Lightfoot v. State of Alabama)

July 12, 2013152 So. 3d 445

Summary

The Alabama Supreme Court held that an Apprendi error in applying a firearm sentencing enhancement is not automatically harmless even when the total sentence does not exceed the statutory maximum, reversed the Court of Criminal Appeals' sentence, and remanded for a new sentencing hearing. Justice Shaw dissented in part, arguing the harmless‑error analysis should not be applied, while Justice Murdock concurred in the result.