Conley v. Pate.

Summary

The court reversed the habeas court’s grant of relief on all asserted grounds. It held that the statutory-rape misdemeanor exception did not apply because the victim was 13, that the 20-year sentence was not grossly disproportionate when evaluated in light of the threatening and violent circumstances, and that the Youthful Offender Act claim was not cognizable in habeas corpus. The court also concluded that it was unnecessary to resolve procedural default because Pate was not entitled to relief on the merits. Peterson, J., concurring, agreed with the result but questioned whether Georgia’s cruel-and-unusual-punishment analysis should follow federal doctrine rather than the original public meaning of the Georgia Constitution.