Terrance Proctor v. Dexter Payne

Summary

The court affirmed dismissal of Proctor’s third habeas petition. It held that his challenge to retroactive application of the Fair Sentencing of Minors Act concerned parole eligibility and was not cognizable in habeas, while his disproportionality claims either had already been decided or required an inquiry beyond the face of the sentencing orders. The court also held that alleged trial errors did not establish facial invalidity or lack of jurisdiction.