Ex Parte Randle

David Randle was convicted of escape in the first degree on July 26, 1984. At his sentencing hearing, the State moved to invoke the Habitual Felony Offender Act, Ala. Code 1975, §13A-5-9, and pursuant thereto the State offered into evidence proof of Randle's four prior felony convictions. The trial court admitted the evidence of the convictions, granted the motion, and sentenced Randle to a mandatory term of life in prison pursuant to § 13A-5-9(c)(2).

On appeal, the Court of Criminal Appeals held that two of the four convictions were improperly proven because they were not properly certified…