Ex Parte Michael Brandon Kelley (in Re Michael Brandon Kelley v. State of Alabama)

Summary

The Alabama Supreme Court held that the Court of Criminal Appeals lacked jurisdiction to review Michael Brandon Kelley’s sexual‑torture conviction because no judgment of conviction—defined as a pronouncement of guilt and a sentence—was entered for that offense. The Court affirmed that this lack of jurisdiction does not invalidate the Court of Criminal Appeals’ review of Kelley’s capital‑murder convictions, which were properly before it, and therefore reversed the lower court’s affirmation of the sexual‑torture conviction and remanded for further proceedings.