Bobby J. Gibbs v. Dexter Payne

Summary

The court affirmed dismissal of Gibbs’s habeas petition challenging his mandatory life-without-parole sentence for a murder committed when he was eighteen. It held that the sentence was not facially illegal under the juvenile-sentencing rule he invoked, so the claim was not cognizable in habeas proceedings and did not establish probable cause of illegal detention. The court also held that he was not entitled to an evidentiary hearing because he failed to show probable cause for issuance of the writ.